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                 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.