HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________                   harttrinen@aol.com
Will Hart                       (303) 839-0061               Fax: (303) 839-5414


                                  June 24, 2013


Norman von Holtzendorff
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   Vanguard Energy Corporation
            Registration Statement on Form S-3
            File No. 333-187697

     This office represents Vanguard Energy Corporation (the "Company").

     Amendment No. 1 to the above  captioned  registration  statement  have been
filed with the Commission. In response to the staff's letter of May 6, 2013:

     o    the  Company is  relying  on Rule 415  (a)(1),  Rule  415(a)(iii)  and
          General  Instruction  I.B.4.  (a)(3) to Form S-3 for  purposes  of the
          transaction, and

     o    the Company's has revised the shares it is registering. The Company is
          not  registering  any shares  issuable  upon the  exercise of warrants
          which are not outstanding.

     If you should have any questions  concerning the  foregoing,  please do not
hesitate to contact the undersigned.

                                Very Truly Yours,

                                HART & HART, LLC

                               /s/ William T. Hart

                             By
                                William T.  Hart