February 23, 2012
Via EDGAR
Mr. H. Roger Schwall
Assistant Director
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Penn Virginia Corporation |
Form 10-K for Fiscal Year Ended December 31, 2010
Filed February 28, 2011
File No. 1-13283
Dear Mr. Schwall:
On February 16, 2012, the Staff of the Securities and Exchange Commission (the Staff) issued a comment letter to Penn Virginia Corporation (the Company) regarding the Companys Annual Report on Form 10-K for the fiscal year ended December 31, 2010. The responses provided below are numbered to correspond to the Staffs comments, which have been reproduced here for ease of reference.
Form 10-K for the Fiscal Year Ended December 31, 2010
Oil and Gas Properties, page 15
1. | We note your response to prior comment 3. Please provide that information in your Form 10-K. We note that leases for 31.8% of your gross acreage (15.8% of your net acreage) expire in 2013. |
Response: The Company acknowledges the Staffs comment and will include the information included in the Companys response to prior comment 3 in its upcoming Annual Report on Form 10-K for the year ended December 31, 2011.
In connection with this response letter, the Company acknowledges that:
| the Company is responsible for the adequacy and accuracy of the disclosure in its filings with the Commission; |
United States Securities and Exchange Commission
February 23, 2012
Page 2
| Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Companys filings; and |
| the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please contact me at (610) 687-8900 if you need additional information or would like to discuss any questions or comments.
Sincerely, |
/s/ Steven A. Hartman |
Steven A. Hartman |
Senior Vice President and Chief Financial Officer |
cc: | Nancy M. Snyder |
Caroline Kim