United States securities and exchange commission logo





                           November 27, 2020

       Ryan M. Lance
       Chief Executive Officer
       ConocoPhillips
       925 N. Eldridge Parkway
       Houston, TX 77079

                                                        Re: ConocoPhillips
                                                            Registration
Statement on Form S-4
                                                            Filed November 18,
2020
                                                            File No. 333-250183

       Dear Mr. Lance:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you
       that the company and its management are responsible for the accuracy and
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

                                                        Please contact Irene
Barberena-Meissner at (202) 551-6548 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Energy & Transportation
       cc:                                              Zachary S. Podolsky