June 4, 2019 Don Wallette, Jr. Executive Vice President and Chief Financial Officer ConocoPhillips 925 N. Eldridge Parkway Houston, TX 77079 Re: ConocoPhillips Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 19, 2019 File No. 001-32395 Dear Mr. Wallette: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Natural Resources