United States securities and exchange commission logo August 26, 2022 Ryan M. Lance Chairman and Chief Executive Officer ConocoPhillips 925 N. Eldridge Parkway Houston, TX 77079 Re: ConocoPhillips Registration Statement on Form S-4 Filed August 18, 2022 File No. 333-266960 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 Arthur Tornabene-Zalas at (202) 551-3162 or Irene Barberena-Meissner, Staff Attorney, at (202) 551-6548 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Keith Townsend, Esq.