SecProbe.io

December 11, 2024
Mark Scucchi
Chief Financial Officer
RANGE RESOURCES CORP
100 Throckmorton Street Suite 1200
Fort Worth, Texas 76102
Re:RANGE RESOURCES CORP
Form 10-K for Fiscal Year Ended December 31, 2023
Filed February 21, 2024
Form 8-K Filed October 23, 2024
File No. 001-12209
Dear Mark Scucchi:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            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.
Form 10-K for Fiscal Year Ended December 31, 2023
Business and Properties
Proved Reserves
Proved Undeveloped Reserves, page 6
1.Please expand your explanation of the 2023 changes in proved undeveloped reserves
due to revisions of previous estimates  to disclose separate volumes for the unrelated
changes due to "previously proved undeveloped properties added back to the five-year
development plan” and "positive revisions for the impact of improved well
performance and longer lateral lengths.” Your disclosure of revisions should 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.

December 11, 2024
Page 2
2.We note the Company has disclosed year-on-year revisions averaging a negative 12%
of the opening balance over the past five years for reclassifying proved undeveloped
reserves to unproved because previously planned wells are not expected to be drilled
within their original five-year development horizon. Simultaneously, there have been
year-on-year additions of new proved undeveloped reserves averaging a positive 15%
due to extension and discoveries, as well as other positive revisions for previously
disclosed proved undeveloped reserves added back to the five-year development plan
during fiscal 2023 and 2022. Please tell us if your development plan for each of the
last five years has been adopted by management and approved by the board. If so,
refer to Rule 4-10(a)(22) and (31)(ii) of Regulation S-X and Question 131.04 in the
Compliance and Disclosure Interpretations (“C&DIs”) relating to Oil and Gas Rules,
and tell us your rationale for this continued trend.
3.You disclose that 90.2 Bcfe of proved undeveloped reserves, as of December 31,
2023, have been reported for more than five years since their original disclosure as
proved undeveloped reserves. We note similar disclosure in your prior annual reports
on Form 10-K. Please expand your disclosure to explain the reasons for the delay and
identify the specific circumstances that justify a time period longer than five years.
Refer to Rule 4-10(a)(31)(ii) of Regulation S-X and Question 131.03 in the
Compliance and Disclosure Interpretations (C&DIs) regarding Oil and Gas Rules,
respectively.
Gross and Net Acreage, page 9
4.We note disclosure that you maintain a multi-year drilling inventory and that 36% of
your total proved reserves, as of December 31, 2023, are undeveloped; however, you
classify the significant majority (92.4%) of your acreage in Pennsylvania as developed
acreage. Please note undrilled acreage or acreage held by production should be
classified as undeveloped acreage for purposes of disclosure under Item 1208(b) of
Regulation S-K. Please modify your disclosure as necessary to resolve any
inconsistencies in the classification of your acreage. Refer to Item 1208(b) and (c)(4)
of Regulation S-K.
Glossary of Certain Defined Terms, page 20
5.•Please revise your glossary to:
oExpand the definition of an “exploratory well” to include the additional
clarification, “Generally, an exploratory well is any well that is not a
development well, an extension well, a service well, or a stratigraphic test
well,” as presented in Rule 4-10(a)(13) of Regulation S-X.
oInclude the definition of an “extension well” as presented in Rule 4-10(a)(14)
of Regulation S-X.

December 11, 2024
Page 3
Management's Discussion and Analysis of Financial Condition, Cash Flows, Capital
Resources and Liquidity
Proved Reserves, page 50
6.Please expand your explanation of the 2023 changes in proved reserves due
to revisions of previous estimates  to include the volume change associated with the
statement “partially offset by negative pricing revisions.” This comment also applies
to the same explanation provided on page F-35 for 2023 and for the positive pricing
revisions in 2022. Your disclosure of revisions should include all contributing factors,
both positive and negative, so the entire volume change is explained. Refer to the
disclosure requirements in FASB ASC 932-235-50-5(a).
Notes to Consolidated Financial Statements
(15) Supplemental Information on Natural Gas and Oil Exploration, Development and
Production Activities (Unaudited)
Estimated Quantities of Proved Oil and Gas Reserves, page F-34
7.Please expand your disclosure of the net quantities of proved developed reserves and
proved undeveloped reserves to include the beginning period of the reserve
reconciliation, e.g. December 31, 2020. Refer to the disclosure requirements in FASB
ASC 932-235-50-4.

Form 8-K Filed October 23, 2024
Exhibit 99.1, page 1
8.We note that “GAAP revenues and other income for third quarter 2024 totaled $615
million” and that “Non-GAAP revenues for third quarter 2024 totaled $680 million."
We also note that you reconciled Total revenues and other income, as reported of
$615 million to Total revenues, as adjusted, non-GAAP of $680 million on page
9. Please tell us how you determined that Derivative fair value income, ARO
settlement loss, interest income and other income are revenue. See Question 100.04 of
the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures
dated December 13, 2022.
9.We note you present Cash margin as a non-GAAP measure which is reconciled to
Income before income taxes, as reported, as the most directly comparable GAAP
measure. Please clarify for us whether Cash margin is a performance measure or a
liquidity measure and why you believe Income before income taxes, as reported, is the
most directly comparable GAAP measure.
            In closing, 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.

December 11, 2024
Page 4
            Please contact Steve Lo at 202-551-3394 or Kimberly Calder at 202-551-3701 if you
have questions regarding comments on the financial statements and related matters.  You may
contact Sandra Wall at 202-551-4727 or John Hodgin at 202-551-3699 for questions
regarding the engineering comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:David Goldberg