Correspondence 0000101778-24-000103 from MARATHON OIL CORP (MRO) (CIK 0000101778)
MARATHON OIL CORP (MRO) (CIK 0000101778)
Date: May 16, 2024 · CIK: 0000101778 · Accession: 0000101778-24-000103
AI Filing Summary & Sentiment
File numbers found in text: 001-05153
Referenced dates: May 3, 2024
Letter
Via EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation Re: Marathon Oil Corporation Form 10-K for Fiscal Year Ended December 31, 2023 Filed February 22, 2024 File No. 001-05153
Dear Ms. Wall and Mr. Skinner:
On behalf of Marathon Oil Corporation (“Marathon Oil”), we acknowledge receipt of the comment letter from the staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission, dated May 3, 2024 (the “Comment Letter”), concerning Marathon Oil’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023, filed on February 22, 2024. Set forth below is the response from Marathon Oil to the Comment Letter.
For convenience of the Staff’s review, we have set forth below in bold type the numbered comment of the Staff in the Comment Letter, with Marathon Oil’s response thereto immediately following the comment.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 8. Financial Statements and Supplementary Data
Supplementary Information on Oil and Gas Producing Activities (Unaudited)
Estimated Quantities of Proved Oil and Gas Reserves
Changes in Proved Undeveloped Reserves, page 105
1.Please expand your explanation of the changes in proved undeveloped reserves due to revisions of previous estimates to include the unexplained net volume decrease of 6 MMBoe. Include all contributing factors, both positive and negative, so the entire volume change is explained. Refer to the disclosure requirements in Item 1203(b) of Regulation S-K.
Response: We have reviewed Item 1203(b) of Regulation S-K and respectfully acknowledge the Staff’s comment. The previously unexplained net volume decrease of 6 MMBoe relates to decreases in commodity prices. In future filings, we will ensure the entire change in the volume of proved undeveloped reserves is explained.
2.Please expand your disclosure of proved undeveloped reserves converted to proved developed to include the associated capital expenditures. Refer to the disclosure requirements in Item 1203(c) of Regulation S-K.
Response: We have reviewed Item 1203(c) of Regulation S-K and respectfully acknowledge the Staff’s comment. We expended capital of approximately $1,070 million to transfer 92 MMBoe of proved undeveloped reserves to proved developed reserves during the year.
In future filings, we will include disclosure of capital expenditures associated with the quantities of proved undeveloped reserves converted to proved developed reserves in the reporting period.
If you have any questions, please do not hesitate to contact the undersigned at 713-296-4140.
Sincerely,
/s/ Zach B. Dailey
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990 Town and Country Boulevard
Houston, TX 77024-2217
Telephone: 713-629-6600
May 16, 2024
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
100 F Street, N.E.
Washington, D.C. 20549
Attn: Ms. Sandra Wall
Mr. Brad Skinner
Re: Marathon Oil Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
Filed February 22, 2024
File No. 001-05153
Dear Ms. Wall and Mr. Skinner:
On behalf of Marathon Oil Corporation (“Marathon Oil”), we acknowledge receipt of the comment letter from the staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission, dated May 3, 2024 (the “Comment Letter”), concerning Marathon Oil’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023, filed on February 22, 2024. Set forth below is the response from Marathon Oil to the Comment Letter.
For convenience of the Staff’s review, we have set forth below in bold type the numbered comment of the Staff in the Comment Letter, with Marathon Oil’s response thereto immediately following the comment.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 8. Financial Statements and Supplementary Data
Supplementary Information on Oil and Gas Producing Activities (Unaudited)
Estimated Quantities of Proved Oil and Gas Reserves
Changes in Proved Undeveloped Reserves, page 105
1.Please expand your explanation of the changes in proved undeveloped reserves due to revisions of previous estimates to include the unexplained net volume decrease of 6 MMBoe. Include all contributing factors, both positive and negative, so the entire volume change is explained. Refer to the disclosure requirements in Item 1203(b) of Regulation S-K.
Response: We have reviewed Item 1203(b) of Regulation S-K and respectfully acknowledge the Staff’s comment. The previously unexplained net volume decrease of 6 MMBoe relates to decreases in commodity prices. In future filings, we will ensure the entire change in the volume of proved undeveloped reserves is explained.
2.Please expand your disclosure of proved undeveloped reserves converted to proved developed to include the associated capital expenditures. Refer to the disclosure requirements in Item 1203(c) of Regulation S-K.
Response: We have reviewed Item 1203(c) of Regulation S-K and respectfully acknowledge the Staff’s comment. We expended capital of approximately $1,070 million to transfer 92 MMBoe of proved undeveloped reserves to proved developed reserves during the year.
In future filings, we will include disclosure of capital expenditures associated with the quantities of proved undeveloped reserves converted to proved developed reserves in the reporting period.
If you have any questions, please do not hesitate to contact the undersigned at 713-296-4140.
Sincerely,
/s/ Zach B. Dailey
Zach B. Dailey
Vice President, Controller and Chief Accounting Officer
Marathon Oil Corporation