Harvest Natural Resources, Inc.
1177 Enclave Parkway, Suite 300
Houston, Texas 77077
November 10, 2010
BY EDGAR
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Securities and Exchange Commission |
Division of Corporation Finance |
100 F Street, N.E. |
Washington, D.C. 20549 |
Attention: | | John Lucas |
| | James Giugliano |
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Re: | | Harvest Natural Resources, Inc. |
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| | Form 10-K for Fiscal Year Ended December 31, 2009 |
| | Filed March 16, 2010 |
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| | Schedule 14A |
| | Filed April 9, 2010 |
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| | Form 10-Q for Fiscal Quarter Ended June 30, 2010 |
| | Filed August 9, 2010 |
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| | File No. 001-10762 |
Ladies and Gentlemen:
In its letter dated August 20, 2010, the staff (“Staff”) of the Securities and Exchange Commission (the “Commission”) provided to Harvest Natural Resources, Inc. (the “Company”) comments with respect to the Company’s (a) Annual Report on Form 10-K for the year ended December 31, 2009, (b) Proxy Statement on Schedule 14A filed on April 9, 2010 and (c) Quarterly Report on Form 10-Q for the quarter ended June 20, 2010. By letter to the Commission dated September 14, 2010, the Company responded to those comments. In its letter dated November 1, 2010, the Staff responded to the Company’s September 14, 2010 letter and provided additional comments (the “Comments”) and asked for responses to the Comments within 10 business days.
The Company respectfully requests additional time to respond to the Comments, and expects to provide such responses on or before November 22, 2010.
If any member of the Staff has any questions concerning the Company’s request, he or she should contact the undersigned at (281) 899-5710.
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| Very truly yours, | |
| /s/ Keith L. Head | |
| Vice President and General Counsel | |
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