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

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
      March 20, 2006


Mr. Charles T. Goodson
Chairman, President and Chief Executive Officer
PetroQuest Energy, Inc.
400 E. Kaliste Saloom Road, Suite 6000
Lafayette, Louisiana, 70508

Re:	PetroQuest Energy, Inc.
      Form S-3
      	Filed February 21, 2006
      	File No. 333-131955

Dear Mr. Goodson:

      We have limited our review of your filing on Form S-3 to the
matters set forth below and have the following 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 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
filings.
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.


Registration Statement

Table of Additional Registrants

1. 	We note the three subsidiaries of PetroQuest Energy Inc.
named
as co-registrants.  Please provide the analysis to support your
conclusion that the co-registrants are eligible to use Form S-3 to
register the guarantees.  We may have further comment.

Prospectus

Cover Page of Prospectus

2.	Please add the co-registrants to the cover page and identify
the
securities of PetroQuest Energy that may be guaranteed by them.

General

3.	In the body of the prospectus, please briefly describe the
type
of guarantees that may be issued by the subsidiaries.

Exhibits

Exhibit 5.1, Opinion of Porter & Hedges, L.L.P.

4.	We note that the co-registrants that may issue guarantees are
incorporated in Louisiana and Oklahoma.  We also note that counsel
limits its opinion to the laws of Texas, New York and Delaware.
Please provide an opinion on the validity and binding nature of
the
guarantees under the laws of Louisiana and Oklahoma

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
supplemental information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and response 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 Act
of
1933 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 filings or
in
response to our comments on your filings.

      Please contact Donna Levy at (202) 551-3292 or, in her
absence,
the undersigned at (202) 551-3685 with any other questions.

      Sincerely,


      Tangela Richter
      Branch Chief


cc:	Robert G. Reedy
      D. Levy
Mr. Charles T. Goodson
PetroQuest Energy, Inc.
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