JAMES N. BARBER Attorney at Law Suite 100, Bank One Tower 50 West Broadway Salt Lake City, UT 84101 Telephone: (801) 364-6500 Fax: (801) 364-3406 or (801) 532-3535 E-Mail: Barberjn@aol.com September 20, 1999 Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549-0404 Re: Viking Exploration Inc./Form 10-SB Dear Sirs: This letter is occasioned by the receipt by Viking of a comment letter from your Division related to Viking's Form 10-SB filed August 3, 1999. We appreciate the timely response of your division to this filing. As a result of the filing date, the 60 day comment period will pass before Viking will be able to address the comments. Accordingly, Viking hereby withdraws its aforesaid Form 10-SB filing pending resolution of the pending comments. Thank you for your cooperation in this matter. Very truly yours, /s/James N. Barber James N. Barber Attorney for Viking Exploration Inc.