January 20, 2009

Securities and Exchange Commission                        Sent Via Fax To:
100 F Street, N.E.                                          (202) 772-9217
Wahington, D.C. 20549

Attention:  Tabatha Akins, Staff Accountant
            Division of Corporation Finance

RE:  Chandler (U.S.A.), Inc.
     Item 4.01 Form 8-K
     Filed January 12, 2009
     File No. 001-15135

Dear Ms. Akins:

This letter is in response to your letter dated January 14, 2009 concerning our
Form 8-K referenced above.  I have numbered my responses below to correspond
with the numbers assigned to the comments contained in your letter.

1.  HoganTaylor LLP is registered with the Public Company Accounting Oversight
    Board (PCAOB).  There may have been a slight timing delay at the PCAOB in
    publishing this, but HoganTaylor LLP does appear on their list of
    registered public accounting firms as of Thursday, January 15, 2009.

2.  Chandler (U.S.A.)'s independent auditors, Tullius Taylor Sartain & Sartain,
    changed its name to HoganTaylor effective January 1, 2009.  Effective
    January 7, 2009, it merged its practice with Hogan & Slovacek, P.C. by
    admitting the shareholders of Hogan & Slovacek as partners of HoganTaylor.
    Since Tullius Taylor Sartain & Sartain and HoganTaylor is the same legal
    entity, the information requested by Item 304(a)(3) of Regulation S-K would
    not be applicable.


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3.  You have requested an updated letter from our former accountants, Tullius
    Taylor Sartain & Sartain LLP, as required by Item 304(a)(3) of Regulation
    S-K.  Since Tullius Taylor Sartain & Sartain changed its name to
    HoganTaylor effective January 1, 2009, a currently dated letter supplied
    by that firm would have to be signed "HoganTaylor" as there is no longer
    a firm named "Tullius Taylor Sartain & Sartain."  If it is considered
    necessary, we could file such a letter signed by "HoganTaylor LLP,
    formerly Tullius Taylor Sartain & Sartain LLP", however this was essential
    accomplished within Exhibit 16.1 to our Form 8-K filing.

We believe that the Form 8-K that we filed on January 12, 2009 adequately
reports the required information regarding the merger of these public
accounting firms, and therefore do not believe that an amended Form 8-K is
necessary.  If, however, you feel that we need to file an amended Form 8-K
further clarifying any of the points noted in your comments, please let me
know.  We would be happy to discuss this with you by phone if you would like
to do so.  I can be reached at (405)258-4292 and our audit partner at
HoganTaylor, Randa Vernon, can be reached at (918)938-7418.

In connection with responding to your comments, we acknowledge that:

  -  Chandler USA is responsible for the adequacy and accuracy of the
     disclosure in the filing;
  -  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
  -  Chandler USA 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.

Sincerely,

/s/ Mark C. Hart

Mark C. Hart
Sr. Vice President and
Chief Financial Officer

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