PAULSON INVESTMENT COMPANY, INC.

November 10, 2011

VIA FACSIMILE AND EDGAR

United States Securities & Exchange Commission
Division of Corporate Finance
Mail Stop 4561
100 F Street, N.E.
Washington, DC  20549
      Attn:  Paul Mansour

Via Facsimile and EDGAR

RE:   Vanguard Energy Corporation
      Registration Statement Form S-1, File Number 333-174194


Ladies and Gentlemen:

     In connection with the above referenced  offering and pursuant to the terms
of Rule  418(a)  (7) and (8)  under  Securities  Act of 1933,  as  amended,  the
preliminary  prospectus,  dated July 12, 2011 was distributed in and outside the
United States  during the period from July 12, 2011 to September  13, 2011,  the
preliminary  prospectus  dated September 14, 2011 was distributed in and outside
of the United  States  during the period from  September 14, 2011 to the present
date.

     Approximately  2,600  preliminary  prospectuses,  dated July 12, 2011, were
distributed  to   approximately   500  prospective   Underwriters  and  Dealers.
Approximately  1,300  preliminary  prospectuses  were delivered to approximately
1,200 individuals and approximately 800 preliminary  prospectuses were delivered
to approximately 700 institutional investors.

     Approximately  1,500  preliminary  prospectuses,  dated September 14, 2011,
were  distributed  to  approximately  50 prospective  Underwriters  and Dealers.
Approximately  350 preliminary  prospectuses were delivered to approximately 300
individuals and  approximately  150 preliminary  prospectuses  were delivered to
approximately 100 institutional investors.

     In addition,  the  underwriters are aware of their  obligations  under Rule
15c2-8 of the  Securities  Act of 1934,  as amended,  and have taken  reasonable
steps to ensure compliance with such obligations.


                                          Sincerely,

                                          Paulson Investment Company, Inc.

                                          /s/ Trent D. Davis

                                          Trent D. Davis
                                          Chief Executive Officer

    811 S.W. Naito Parkway, Suite 200, Portland, Oregon 97204, (503)243-6000