February 8, 2006


Mr. Kenneth H. Beer
Senior Vice President and Chief Financial Officer
Stone Energy Corporation
625 E. Kaliste Saloom Road
Lafayette, LA 70508


	Re:	Stone Energy Corporation
		Form 10-K for the Fiscal Year Ended December 31, 2004
Filed March 9, 2005
File No. 001-12074
Response letter dated January 16, 2006



Dear Mr. Beer:

      We have reviewed your response letter and filings and have
the
following comments.  Where indicated, we think you should revise
your
documents 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 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.


Form 10-K for the Fiscal Year Ended December 31, 2004

1. We read your prior response 5 of January 17, 2005.  However, we
believe that you also need to consider other criteria than
reserves
when disclosing significant properties.  See Instruction 2 of Item
102 of Regulation S-K.  For example, you should consider
production
and/or current and future capital expenditures among others.  We
note
in your table of reserves provided to us a number of fields with
higher net reserves and/or production as of September 2005 than
the
significant field you cite and note just nine fields represent 50%
of
your revised reserves.  We note your 2nd and 3rd Quarter 2005
earnings reports where you provide operational updates on no less
than six fields.

2. Tell us what your estimated production for 2005 from your 2004
reserve report was for Proved Developed Producing, Proved
Developed
Non-Producing and Proved Undeveloped reserve categories.

3. Your response number 8 indicates that a material portion of the
reserve write down was due to reservoir parameters you now believe
are too optimistic.  Please provide examples of underperformance
or
non-performance of these reserves when placed on production or
tell
us if these are mostly proved undeveloped reserves.  If they are
primarily undeveloped reserves, tell us why you believe it was the
proper time to revise them before production was established. Tell
us
the percent of the total reserve write-down each example
represents.

4. In response 8 you indicate that a certain percentage of the
reserves you wrote off were because the data did not support
reasonable certainty.  Please provide more information on these
examples such as how, in your opinion, the data for each example
did
not support reasonable certainty.

5. In response 9 the footnote to the supplemental table indicates
that the pre-drill EUR`s represent potential reserves and not SEC
reserve estimates.  Our comment may not have been clear as we
intended to request the pre-drill reserve estimates that were
booked
as proved undeveloped reserves and reported as such in your SEC
filings prior to drilling.  Please provide those estimates for the
listed wells.


Closing Comments

       As appropriate, please amend your filings 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 Mark A. Wojciechowski at (202) 551-3759 or,
in
his absence, Karl Hiller at (202) 551-3686 if you have questions
regarding comments on the financial statements and related
matters.
You may contact James Murphy, Petroleum Engineer, at (202) 551-
3703
if you have questions related to engineering issues and related
disclosures.  Please contact me at (202) 551-3740 with any other
questions.


      Sincerely,


								H. Roger Schwall
							Assistant Director
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Mr. Kenneth H. Beer
Stone Energy Corporation
February 8, 2006
Page 1




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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010