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


                                  July 9, 2013

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

      Re:   Vanguard Energy Corporation
            Post-Effective Amendment #4 to Form S-1
            File No. 333-174194

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

     Post-Effective  Amendment #4 to the above captioned  registration statement
has been filed with the Commission. The following are the Company's responses to
the Staff's letter dated June 28, 2013:

     1. In December 2011, in its initial public offering, the Company sold:

          o    4,800,000 shares of common stock;

          o    4,800,000 Class A warrants; and

          o    Underwriters'  warrants.  The  Underwriters'  warrants  allow the
               holders to purchase  up to 480,000  units at a price of $1.20 per
               unit at any time prior to February 28, 2016.  Each unit  consists
               of one  share  of the  Company's  common  stock  and one  Class A
               warrant.

     None of the Class A warrants and none of the  underwriters'  warrants  have
been exercised.  The table accompanying the Explanatory Note has been revised in
this respect.

     2. The wording which is the subject of this comment has been revised.

     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