March 28, 2011
BY FEDERAL EXPRESS
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, Mail Stop 7010
Washington, DC 20549
Attn:  Ethan Horowitz and Suying Li

RE:   Amerigo Energy, Inc.  - Form 8-K Filed March 18, 2011

Dear Mr. Horowitz and Ms. Li:

      On  behalf of registrant, Amerigo Energy, Inc., we hereby respond to your
comment letter  of  March  22, 2011 in the same sequence in which your comments
are noted.

   1. Your disclosure stating  that  your former auditor, Larry O'Donnell, CPA,
      P.C.'s  registration  with the Securities  and  Exchange  Commission  was
      revoked. Please amend your  filing  to  state  that  the  Public  Company
      Accounting   Oversight   ("PCAOB")  revoked  the  registration  of  Larry
      O'Donnell, CPA, P.C. effective December 14, 2010.
           a. The disclosure has been updated.
   2. Please  revise your filing  to  explicitly  state  the  date  that  Larry
      O'Donnell,  CPA,  P.C.  was  dismissed and whether the decision to change
      accountants was recommended or  approved  by  1)  any  audit  or  similar
      committee  of  the  board of directors; or 2) the board of directors.  We
      refer you to the guidance  at  Items 304(a)(1)(i) and (iii) of Regulation
      S-K.
           a. We have amended our filing  to  state  the  date  at  which Larry
              O'Donnell, CPA, P.C. was dismissed by the company.
           b. We already addressed the decision to change accountants  and  how
              it was approved by the board of directors in the second paragraph
              in section 4.

In addition, the Company acknowledges that:
the  Company  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 the company 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.


Date: March 28, 2011
By: /s/ Jason F. Griffith
Jason F. Griffith
Its: Chief Executive Officer, Chief Financial Officer and Director