-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, WRMfG6MHC8KjUsvoK03pnyA7Kza7QfukBC9RIV9E0ER7fwueRqs9lM14q91yUoaI 7Gb4biIK7pFGish6o9ACKg== 0000077159-05-000054.txt : 20060927 0000077159-05-000054.hdr.sgml : 20060927 20050707120008 ACCESSION NUMBER: 0000077159-05-000054 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050707 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PENN VIRGINIA CORP CENTRAL INDEX KEY: 0000077159 STANDARD INDUSTRIAL CLASSIFICATION: CRUDE PETROLEUM & NATURAL GAS [1311] IRS NUMBER: 231184320 STATE OF INCORPORATION: VA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 MATSONFORD ROAD SUITE 300 STREET 2: THREE RADNOR CORPORATE CENTER CITY: RADNOR STATE: PA ZIP: 19087 BUSINESS PHONE: 6106878900 MAIL ADDRESS: STREET 1: 100 MATSONFORD ROAD SUITE 300 STREET 2: THREE RADNOR CORPORATE CENTER CITY: RADNOR STATE: PA ZIP: 19087 FORMER COMPANY: FORMER CONFORMED NAME: VIRGINIA COAL & IRON CO DATE OF NAME CHANGE: 19670501 CORRESP 1 filename1.htm

[PENN VIRGINIA CORPORATION LETTERHEAD]

July 7, 2005

Via Facsimile, U.S. Mail and Edgar

Ms. April Sifford
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0405

Re:	Penn Virginia Corporation Form 10-K for Fiscal Year Ended December 31, 2004 Filed on March 11, 2005 File number 1-13283

Dear Ms. Sifford:

On June 23, 2005, the Staff of the Securities and Exchange Commission (the "Staff") issued a comment letter to Penn Virginia Corporation (the "Company") regarding the Company's Form 10-K for the fiscal year ended December 31, 2004.

The Staff's comments and the Company's response thereto are as follows:

Form 10-K for the Fiscal Year Ended December 31, 2004

Financial Statements, page 51

Note 4 - Acquisitions, Page 65

Coal Royalty and Land Management, page 65

1. We have considered your response to our comment two in our letter dated June 1, 2005; however, given the significance of this acquisition to your financial statements, which include the consolidated financial statements of Penn Virginia Resource Partners, L.P., we continue to believe you should file a Form 8-K that includes the historical financial statements of Cantera Natural Gas LLC and related pro forma financial information. Although you followed the precise language of Item 2.01 of Form 8-K, which is applicable to "the registrant or any of its majority-owned subsidiaries," we believe this Item also applies to consolidated subsidiaries. We consider this financial information relevant to investors for purposes of understanding how this acquisition will impact your future operations.

Response: The Company acknowledges the Staff's comments and will file a Form 8-K under Item 8.01, which includes historical financial statements of Cantera Natural Gas LLC and related pro forma financial information for the Company.

Please contact me at (610) 687-8900 if you need additional information or would like to discuss any questions or comments.

Sincerely,

/s/ Nancy M. Snyder

Nancy M. Snyder

Senior Vice President and General Counsel

cc:

Frank A. Pici

Jenifer Gallagher

Yong Choi

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