United States securities and exchange commission logo February 24, 2022 Kelly B. Rose Senior Vice President, Legal and General Counsel ConocoPhillips 925 N. Eldridge Parkway Houston, TX 77079 Re: ConocoPhillips Registration Statement on Form S-4 Filed February 17, 2022 File No. 333-262829 Dear Ms. Rose: 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 Arthur Tornabene-Zalas at (202) 551-3162 or Anuja Majmudar, Attorney- Advisor, at (202) 551-3844 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Zachary S. Podolsky, Esq.