================================================================================ Kodiak Energy, Inc. 734 7th Avenue S.W., Suite 460 Calgary, Alberta T2P 3P8 Canada November 21, 2006 VIA EDGAR Mr. Raj Rajan, Staff Accountant Securities and Exchange Commission Mail Stop 3561 100 F Street, NE Washington, DC 20549 Re: Form 8-K, filed November 13, 2006 File No. 333-82434 ---------------------------------- Dear Mr. Rajan: On behalf of the company, Kodiak Energy, Inc. ("Kodiak"), I respond as follows to the Staff's comments received by letter dated November 15, 2006, relating to the above-captioned Form 8-K, filed November 13, 2006. 1. Please amend your filing to disclose the date when you concluded that your financial statements should not longer be relied on. I have amended the Form 8-K to disclose the date on which Kodiak concluded that the financial statements should no longer be relied on. 2. Please revise to state specifically the financial statements should not be relied upon and identify such financial statements that should not be relied upon. I have amended the Form 8-K to state which financial statements should not be relied on. Kodiak acknowledges that: (i) Kodiak is responsible for the adequacy and accurate of the disclosure in the Registration Statement filing referred to above; (ii) The 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 Mr. Raj Rajan November 21, 2006 Page 2 (iii) Kodiak 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. Very truly yours, /s/ Mark Hlady ---------------------------------- Mark Hlady CEO and Director - --------------------------------------------------------------------------------