February 10, 2006                                             VIA FAX and EDGAR

Attention:  Sue Reilly
Securities and Exchange Commission
450 Fifth St. N.W.
Washington D.C.  20549
Tel: (202) 551-3236

RE:      MORGAN CREEK ENERGY CORP.
         Pre-Effective Amendment No. 6 to Form SB-2 (SEC FILE No. 333-123989)

Dear Ms. Reilly:

     On behalf of Morgan Creek Energy Corp.  (the  "Registrant",  "Company"),  I
hereby  request  that   Pre-Effective   Amendment  No.  6  to  the  Registrant's
Registration  Statement  on Form SB-2 become  effective  at 10:00 a.m.  (EST) on
Tuesday, February 14, 2006, or as soon thereafter as possible.

     We hereby acknowledge our responsibilities under the Securities Act of 1933
and the  Securities  Exchange  Act of 1934 as they may  relate  to the  proposed
public offering of the securities specified in the above-referenced Registration
Statement.

     Morgan Creek Energy Corp. acknowledges that:

o    should the  Commission or staff,  acting  pursuant to delegated  authority,
     declare the filing  effective,  it does not foreclose the  Commission  from
     taking any action with respect to the filing;

o    the action of the  Commission  of the staff,  acting  pursuant to delegated
     authority, in declaring the filing effective,  does not relieve the Company
     from  its  full  responsibility  for  the  adequacy  and  accuracy  of  the
     disclosure in the filing; and

o    the  Company  may not assert  this  action as a defense  in any  proceeding
     initiated by the Commission or any person under the federal securities laws
     of the United States.


     Please note that this letter will be filed with the  Commission  via EDGAR.
If you have any  questions or concerns,  please  contact me at the number listed
above.

Yours truly,
Morgan Creek Energy Corp.

/s/Grant Atkins
- -------------------
   Grant Atkins
   CFO, Director