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                             April 24, 2024

       William Bullock, Jr
       EVP and Chief Financial Officer
       ConocoPhillips
       925 N. Eldridge Parkway
       Houston, TX 77079

                                                        Re: ConocoPhillips
                                                            Form 10-K for the
Fiscal Year ended December 31, 2023
                                                            Filed February 15,
2024
                                                            File No. 001-32395

       Dear William Bullock:

              We have reviewed your April 3, 2024 response to our comment
letter and have the
       following comment.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our March 22, 2024
       letter.

       Form 10-K for the Fiscal Year ended December 31, 2023

       Management's Discussion and Analysis
       Income Statement Analysis, page 41

   1.                                                   We note your response
to prior comments one and two, indicating that you believe no
                                                        incremental discussion
and analysis should be necessary because you operate a
                                                        commodity business and
have already provided a qualitative discussion of the pricing
                                                        environment and
reported average daily production volumes and average unit prices,
                                                        which you regard as the
relevant "primary material activity drivers."

                                                        You indicate that such
disaggregated quantitative information allows investors to view the
                                                        business from
management   s perspective, though do not explain why you believe that a
                                                        discussion and analysis
of annual revenues and annual production in an annual report
                                                        would not also be
essential or fundamental to the view, and material to an assessment of
 William Bullock, Jr
ConocoPhillips
April 24, 2024
Page 2
         your results of operations. You do not explain why you believe the
requirement for the
         discussion and analysis to be "of the financial statements" could
accommodate a narrative
         that excludes key financial measures that are required to be reported
in your financial
         statements under generally accepted accounting principles.

         With regard to the reasons for material changes in line items, you
indicate that you are
         using the terms "primarily" or "partially offset by" when describing
such reasons and that
         the absence of quantification "conveys the concept that no individual
item needs to be
         quantified to assist the reader in understanding a variance." However,
you have not
         explained how your concept on need reconciles to the requirement to
describe such
         reasons in both quantitative and qualitative terms, nor shown how the
concept has been
         applied in determining whether you would provide quantification.

         We continue to believe that substantial revisions will be necessary to
address our prior
         comments, to include a discussion and analysis of the periodic
activity that is reported in
         your financial statements for each period, and the total volumes of
production underlying
         annual sales/revenues. We re-issue prior comments one and two.
       Please contact Mark Wojciechowski at 202-551-3759 or Karl Hiller at
202-551-3686 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameWilliam Bullock, Jr                          Sincerely,
Comapany NameConocoPhillips
                                                               Division of
Corporation Finance
April 24, 2024 Page 2                                          Office of Energy
& Transportation
FirstName LastName