July
12,
2005

via facsimile and U.S. mail

Mr. Vaughn Barbon
Chief Financial Officer
Lexington Resources, Inc.
7473 West Lake Mead Road
Las Vegas, Nevada 89128

Re:	Lexington Resources, Inc.
		Form 10-KSB for year ended December 31, 2004
		Filed March 31, 2005
		File No. 0-25455

Dear Mr. Barbon:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please provide a
written
response to our comments.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the Year Ended December 31, 2004

Independent Auditor

Location of Auditor, page F-2

1. We note that your audit report was signed by an audit firm
based
in Vancouver, Canada.  Please tell us how you concluded that it is
appropriate to have engaged an auditor licensed outside of the
United
States, in light of the facts that the majority of your assets
appear
to be located within; the majority of your revenues are derived
within, and your corporate offices are located within the United
States.  We believe the guidance in Article 2 of Regulation S-X
ordinarily requires that the audit report of a registrant (that is
not a foreign private issuer) to be rendered by an auditor
licensed
in the United States.  Further guidance may be found in Section
5.K
of "International Reporting and Disclosure Issues in the Division
of
Corporation Finance on our website at
http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm
#P4
42_69217Please.

Auditor`s Report, page F-2

2. The third paragraph of the auditor`s report (opinion paragraph)
should be revised to include a sentence identifying what GAAP used
in
preparing the financial statements.

Financial Statement Footnotes

3. Revise to provide the unaudited supplemental disclosure for oil
and gas properties required by SFAS 69.

Exhibit 32.1 Certification Under Section 906

4. The certification required in this exhibit must correspond to
the
name of the registrant.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact John A. Weitzel, Staff Accountant at (202)
551-
3731 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3686
with any other questions.

								Sincerely,



								Karl Hiller
								Branch Chief

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Mr.Vaughn Barbon
Lexington Resources, Inc.
July 12, 2005
Page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010