SUN RIVER ENERGY, INC.
                           10200 W. 44th, Suite 210-E
                              WheatRidge, CO 80033

                                 (303) 940-2090

                                May 14, 2007



SEC
Attn: Raquel Howard
Mail Stop 3561
450 5th St., N.W.
Washington, D.C. 20549-0405


Re:      Sun River Energy, Inc. - File No. 000-27485

     In response to your comment letter dated April 4, 2007, Sun River Energy,
Inc. acknowledges to the SEC that:


          1.   The Company is  responsible  for the adequacy and accuracy of the
               disclosure in their filings;

          2.   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

          3.   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.

     We hope this satisfies your requirement.

     If you have any questions, please let me know.


                                                  Sincerely,


                                                  /s/ Wesley F. Whiting
                                                  ---------------------
                                                  Wesley F. Whiting