THE O'NEAL LAW FIRM, P.C.
                            17100 East Shea Boulevard
                                   Suite 400-D
                          Fountain Hills, Arizona 85268
                              (480) 812-5058 (Tel)
                              (480) 816-9241 (Fax)


                                February 6, 2006

Susann Reilly
Securities and Exchange Commission
100 F Street, N.W.
Mail Stop 3561
Washington, D.C. 20549

Re:  Morgan Creek Energy Corp.
     Registration Statement on Form SB-2 (Fifth Amendment)
     File No.  333-123989
     Filed August 18, 2005

Dear Ms. Reilly:

We are writing in response to your  comment  letter dated  January 31, 2006,  in
connection  with the  above-referenced  filing.  The  numbered  responses  below
correspond to your numbered comments based upon the clean copy provided to you.

     1.  Liquidity and Capital  Resources,  page 22. We have inserted a table of
     services that were to be performed by American News Publishing,  Inc. prior
     to the rescission of the agreement. We have also included a disclosure that
     there was no written agreement for these services. The agreement was verbal
     based  upon  a  prior  working  relationship  between  certain  members  of
     management and American News Publishing,  Inc. unrelated to the company. We
     have further disclosed that on January 20, 2006, the company has received a
     full refund of the $200,000 fee advanced to American News Publishing, Inc.e
     have further  included the letter from American News Publishing  rescinding
     the agreement as Exhibit 4.7. As the  agreement has been  rescinded and all
     funds advanced have been repaid,  we believe this should fully resolve this
     issue  as it is no  longer  material  to  the  on-going  operations  of the
     company.

     2. Description of Business, page 26. We believe this comment is moot as the
     entire  $200,000  fee has been  refunded to the  company by  American  News
     Publishing, Inc. We have included a disclosure to that effect.

     3. Security Ownership of Certain Beneficial Owners and Management, page 41.
     We have revised this section to include the beneficial  holdings of Newport
     Capital Corp.

Please do not hesitate to contact us if you have any further questions.

Very truly yours,



/s/ William D. O'Neal
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    William D. O'Neal