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   QUANTUM ENERGY
   OTCBB:QEGY
   Frankfurt: B&A


   Mr. Kevin Stertzel
   United States Securities and Exchange
   Commission Washington, D.C. 20549-0405



     February 26, 2007

    Attention: Kevin Stertzel, Division of Corporate Finance
    ---------------------------------------------------------

Dear Sirs,

    RE: Quantum Energy Inc. (the "Company")
        Form 10-QSB for the fiscal quarter ended May 31, 2006
        Form 8K filed May 24, 2006
        --------------------------

    We are writing in 'reply to your comment  letter dated January 23, 2007. The
    following are our responses.

    Form 8-K Filed, May 24; 2006
    ----------------------------

Comment:

    1.  We note your Form 8-K that  appears to indicate  your  acquisition  of
        KOKO Petroleum,  Inc.'s  producing oil and gas assets.  We are unable to
        locate related financial statements and pro forma infortnation  required
        under Rules 3-05 and  11-01(a)  of  Regulations  S-X.  Also refer to SAD
        Topic 2:D, questions 4 and 7 for additional.  guidance.  Please file the
        necessary financial statements and pro forma financial.  information. or
        otherwise,  please tell us why you don't  believe  this  information  is
        necessary.  Include with your pro forma  disclosures,  a presentation of
        pro forma reserve  information in a roll-forward  format and a pro forma
        standardized  measure.  Please  refer to SFAS 69 for formats  of these
        disclosures.

   Response:

   Please  Find  attached  edited  8K form  which  now  includes  the  financial
  information required.





Quantum energy, Inc.                                  Toll-Free: (880 74O-7276
PO Box 929                                    Email: info(quonlumenorgylnc.net
Penticton, BC
V2A 6J9                                          Web: www.quontumenergyinc.net

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QUANTUM ENERGY
OTCBI:QEGY
Frankfurt:B&A



         Form 10-QSB for the Fiscal Quarter Ended May 31, 2006
         -----------------------------------------------------

Comment:

2. it appears that you have changed the focus of your business to an enterprise
engaged in the exploration for; and the development and production of oil and
gas. Please tell us how you have considered. expanding your accounting policy
disclosures to include your accounting policy for oil and gas activities. Please
refer to SPAS 19 or Rule 4-010 or Regulation S-X for additional guidance. In
addition, please be advised of the annual. reporting requirements found in. SPAS
69.

Response:


SFAS 69 has been  reviewed by  Management  and the Company  will comply with all
required disclosures; including reporting oil and gas reserves. The following is
management's  suggestion of the disclosure to be made in the Form l0-QSB's notes
to  financial   statements  (Note  3(h))  regarding  to  the  accounting  policy
disclosures.

"The Company uses the  successful  efforts method of accounting for oil. and gas
producing  activities.  Costs  to  acquire  mineral  interests  in oil  and gas
properties,  to drill and equip exploratory wells that find proved reserves,  to
drill and equip development wells and related asset retirement. Costs to
drill  exploratory  wells  that do not find  proved  reserves,  geological  and
geophysical costs, and costs of carrying and retaining unproved properties are
expensed.

Unproved  oil  and  gas  properties  that  are   individually   significant  are
periodically  assessed for impairment of value,  and a loss is recognized at the
time  of  impairment  by  providing  an  impairment  allowance.  Other  unproved
properties  are  amortized  based  on the  Company's  experience  of  successful
drilling and average holding period.  Capitalized costs of producing oil and gas
properties, after considering estimated residual salvage values, are depreciated
and  depleted by the  unit-of-production  method.  Support  equipment  and other
property attn. equipment are depreciated over their estimated useful lives.

On the sale or retirement of a complete unit of a proved property, the cost and
related accumulated depreciation, depletion, and amortization are eliminated
from the property accounts, and the resultant gain. or loss is recognized. On
the retirement or sale of a partial. unit of proved property, the cost is.
charged to


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QUANTUM ENERGY
OTCBI:QEGY
Frankfurt:B&A


accumulated  depreciation,  depletion, and amortization with a resulting gain or
loss recognized in income.

On the sale of an entire  interest  in an  unproved  property  -for cash or cash
equivalent,  gain or loss on the sale is recognized,  taking into consideration.
the  amount  of any  recorded  impairment  if the  property  had  been  assessed
individually.  If a partial interest in an unproved property is sold, the amount
received is treated as a reduction of the costs off the interest retained."


Please find  enclosed the  financial  statement of KOKO  Petroleum  Inn. for the
years  ending  August 31,  2005 and.  2006  (audited)  and the six months  ended
November 30 2005 and 2004 (unaudited) and amended notes to financial  statements
for the form 1OQSB/A (note 3(h)) for your review and, comments.

The reserve reports are not available at this date, however, the Company engaged
Mr. John M. Durkee, a. qualified engineer,  to provide such a report.  According
to the letter  agreement  enclosed  with this reply the reserve  reports will be
available within. 60 calendar days from February 20, 2007.






Very truly Yours,



By: /s/ Ted Kozub
- ------------------
Ted Kozub, CEO
Quantum Energy Inc.




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