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CORRESP
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Gulfport
Energy Corporation

713
Market Drive

Oklahoma
City, Oklahoma 73114

January
9, 2023

VIA
EDGAR

United
States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Ethan Horowitz, Accounting Branch Chief

    Jennifer O’Brien, Staff Accountant

    John Hodgin, Petroleum Engineer

 Re: Gulfport
                                            Energy Corporation

Form
10-K for Fiscal Year Ended December 31, 2021

Form
8-K filed November 1, 2022

File
No. 001-19514

To
the addressees set forth above:

This
letter sets forth the responses of Gulfport Energy Corporation (the “Company,” “we,”
“our” and “us”) to the comments set forth in the comment letter of the staff of the
Securities and Exchange Commission (the “Staff”) dated December 16, 2022 (the “Comment Letter”)
relating to the Company’s Form 10-K for Fiscal Year ended December 31, 2021 (the “Form 10-K”) and Form
8-K filed November 1, 2022 (the “Form 8-K” and collectively, the “Filings”).

To
assist your review, set forth below in bold are the comments of the Staff contained in the Comment Letter and immediately below each
comment is the response of the Company with respect thereto. Capitalized terms used but not defined herein have the meanings ascribed
to such terms in the Filings, as applicable.

Form
10-K for Fiscal Year Ended December 31, 2021

Definitions,
page ii

 1. We
                                            note disclosure of reserves and production throughout your filing in terms of gas equivalent
                                            amounts. However, you do not appear to have clarified the basis for converting liquid hydrocarbons
                                            to gas equivalent amounts. Please expand your definitions as necessary to comply with Instruction
                                            3 to paragraph (a)(2) of Item 1202 of Regulation S-K.

Response:
The Company respectfully acknowledges the Staff’s comment. The Company converts liquid hydrocarbons to gas equivalent amounts at
the ratio of six Mcf of natural gas to one barrel of oil and will include such information in the applicable definitions in future filings,
beginning with our Form 10-K for the Fiscal Year ended December 31, 2022.

    1

Business

Oil,
Natural Gas and NGL Reserves

Reserves
Estimation, page 8

 2. It
                                            appears that you disclose material additions to your proved reserves for the year ended December
                                            31, 2021. Please expand your disclosure to provide a general discussion of the technologies
                                            used to establish the appropriate level of certainty for your reserves estimates. Refer to
                                            Item 1202(a)(6) of Regulation S-K.

Response:
The Company respectfully acknowledges the Staff’s comment. The Company will expand our disclosure in applicable future filings,
beginning with our Form 10-K for the Fiscal Year ended December 31, 2022, to include a general discussion of the technologies used to
establish the appropriate level of certainty for our reserves estimates for periods in which we have material additions to our proved
reserves estimates.

Production,
Prices and Production Costs, page 12

 3. Please
                                            revise the information presented on pages 12 and 13 as Non-GAAP Combined as this characterization
                                            does not appear to be appropriate.

Response:
The Company respectfully acknowledges the Staff’s comment. While the Company believes our presentation allowed investors to better
understand our underlying business through the Chapter 11 process during the periods presented while clearly indicating that such measure
was a non-GAAP presentation, the Company will cease presenting financial and operational information, including production volumes, average
prices received and average production costs, on a Non-GAAP Combined basis in future filings, beginning with our Form 10-K for the Fiscal
Year ended December 31, 2022.

Management's
Discussion and Analysis of Financial Condition and Results of Operations, page

39

 4. It
                                            appears that you have presented 2021 results and other information as the mathematical addition
                                            of the predecessor (January 1, 2021 to May 17, 2021) and successor periods (May 18, 2021
                                            to December 31, 2021). We also note that you recognize this combined presentation does not
                                            comply with GAAP and has not been prepared as pro forma results under applicable regulations.

This
type of presentation does not appear to be appropriate for periods when fresh start accounting was applied and the characterization of
this information as non-GAAP does not appear to be consistent with Item 10(e) of Regulation S-K. Please tell us why this presentation
is appropriate or remove it and revise the narrative discussion of your operating results.

Response:
The Company respectfully acknowledges the Staff’s comment. While the Company believes our presentation allowed investors to better
understand our underlying business through the Chapter 11 process during the periods presented while clearly indicating that such measure
was a non-GAAP presentation, the Company will cease presenting financial and operational information on a Non-GAAP Combined basis throughout
our future filings, beginning with our Form 10-K for the Fiscal Year ended December 31, 2022, in accordance with Item 10(e) of Regulation
S-K.

    2

Business
and Industry Outlook, page 41

 5. You
                                            state that you have experienced and expect to continue to experience inflationary pressures
                                            during 2022 and that you will continue to monitor and manage inflationary pressures caused
                                            by increased activities in the field as well as supply chain pressures. Revise to more clearly
                                            discuss whether supply chain disruptions materially affect your outlook or business goals
                                            and how these challenges have impacted your results of operations or capital resources and
                                            quantify, to the extent possible, how your sales, profits, and/or liquidity have been impacted.
                                            In addition, identify actions planned or taken, if any, to mitigate inflationary pressures
                                            and clarify the resulting impact to the company, as applicable.

Response:
The Company respectfully acknowledges the Staff’s comment and will include additional disclosure in applicable future filings,
beginning with our Form 10-K for the Fiscal Year ended December 31, 2022, to more specifically discuss the impacts of inflationary and
supply chain pressures on the Company and our operations and any actions planned or taken by the Company to mitigate such pressures.

Notes
to Consolidated Financial Statements

20.
Supplemental Information on Oil and Gas Exploration and Production Activities (Unaudited)

Oil
and Natural Gas Reserves, page 106

 6. Please
                                            expand the tabular presentation of proved developed and proved undeveloped reserves, by individual
                                            product type, to additionally provide the net quantities at the beginning of the initial
                                            year shown in the reconciliation, i.e. January 1, 2019. Refer to FASB ASC 932-235-50-4.

Response:
The Company respectfully acknowledges the Staff’s comment and will provide three years of reconciliations of proved developed and
proved undeveloped reserves in applicable future filings, beginning with our Form 10-K for the Fiscal Year ended December 31, 2022.

Standardized
Measure of Discounted Future Net Cash Flows Relating to Proved Oil and Gas

Reserves,
page 108

 7. Please
                                            expand the discussion accompanying the presentation of the standardized measure to clarify,
                                            if true, that all estimated future costs to settle your asset retirement obligations have
                                            been included in your calculation of the standardized measure for each period presented.
                                            Refer to FASB ASC 932-235-50-36.

If
the estimated future costs to settle your asset retirement obligations (including the costs related to your proved undeveloped reserves)
have not been included, please explain to us your rationale for excluding these costs from your calculation of the standardized measure,
or revise your disclosure to include these costs.

Response:
The Company respectfully acknowledges the Staff’s comment and advises that all estimated future costs to settle the Company’s
asset retirement obligations have been included in our calculation of the standardized measure for each period presented. The Company
undertakes to revise our disclosure in applicable future filings, beginning with our Form 10-K for the Fiscal Year ended December 31,
2022 to clarify such fact.

    3

Form
8-K filed November 1, 2022

Exhibit
99.2

Non-GAAP
Reconciliations, page 14

 8. Please
                                            provide us with an explanation for presenting Non-GAAP Combined measures for the predecessor
                                            and successor periods identified in your Form 8-K.

Response:
The Company respectfully acknowledges the Staff’s comment. While the Company believes our presentation allowed investors to better
understand our underlying business through the Chapter 11 process during the periods presented while clearly indicating that such measure
was a non-GAAP presentation, the Company will cease presenting financial and operational information on a Non-GAAP Combined basis throughout
our future filings, beginning with our earnings release and supplemental financial information for the fiscal year ended December 31,
2022.

 9. Expand
                                            your disclosure regarding forward-looking non-GAAP measures where you are relying on the
                                            exception per Item 10(e)(1)(i)(B) of Regulation S-K to clearly disclose your reliance on
                                            the exception and to identify the information that is unavailable and its probable significance
                                            in a location of equal or greater prominence. See Question 102.10(b) of the Compliance &
                                            Disclosure Interpretations regarding Non-GAAP Financial Measures.

Response:
The Company respectfully acknowledges the Staff’s comment. The Company will expand our disclosure in applicable future filings,
beginning with our earnings release and supplemental financial information for the fiscal year ended December 31, 2022, to expressly
note our reliance on the exception regarding forward-looking non-GAAP measures included in Item 10(e)(1)(i)(B) of Regulation S-K and
to identify the information that is unavailable and its probable significance in a location of equal or greater prominence.

 10. We
                                            note that a number of your non-GAAP measures include an adjustment for Non-recurring general
                                            and administrative expenses. Please revise to more clearly explain the nature of the amounts
                                            underlying these adjustments.

Response:
The Company respectfully acknowledges the Staff’s comment and will clarify in applicable future filings, beginning with our earnings
release and supplemental financial information for the fiscal year ended December 31, 2022, that non-recurring general and administrative
expenses are comprised of expenses related to the continued administration of our prior Chapter 11 filing.

 11. Please
                                            revise the adjustments to your non-GAAP measures titled "Other, net" to provide
                                            a qualitative and quantitative description of each of the components of these adjustments.

Response:
The Company respectfully acknowledges the Staff’s comment and will clarify in applicable future filings, beginning with our earnings
release and supplemental financial information for the fiscal year ended December 31, 2022, and will include a quantitative description
of such items for the applicable periods presented.

For
reference, “Other, net” included in our “Nine Months Ended September 30, 2022” Adjusted EBITDA reconciliation
included $11.5 million related to our initial claim distribution from our Chapter 11 Plan of Reorganization. The distribution is more
fully described in Note 7 of our unaudited condensed consolidated financial statements included in our Quarterly Report on Form 10-Q
for the quarterly period ended September 30, 2022.

    4

 12. We
                                            note you present Basic and Diluted EPS on Adjusted Net Income. Please reconcile these measures
                                            to GAAP Net Income (Loss) Per Share. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and Question
                                            102.05 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.

Response:
The Company respectfully acknowledges the Staff’s comment and will reconcile our presentations of Basic and Diluted EPS on Adjusted
Net Income to reconcile such measures to GAAP Net Income (Loss) Per Share in applicable future filings, beginning with our earnings release
and supplemental financial information for the fiscal year ended December 31, 2022.

 13. It
                                            appears that the non-GAAP measure Free Cash Flow should be renamed as you do not calculate
                                            it in the typical manner. For additional information, see Question 102.07 of the Compliance
                                            & Disclosure Interpretations regarding Non-GAAP Financial Measures.

Response:
The Company respectfully acknowledges the Staff's comment and advises that Staff that it will retitle our Free Cash Flow metric as “Adjusted
Free Cash Flow” in applicable future filings, beginning with our earnings release and supplemental financial information for the
fiscal year ended December 31, 2022

 14. Revise
                                            your reconciliation from Net Cash Provided by Operating Activities to Adjusted EBITDA to
                                            clarify the nature of the adjustment for Changes in operating assets and liabilities, net.

Response:
The Company respectfully acknowledges the Staff’s comment and in applicable future filings, beginning with our earnings release
and supplemental financial information for the fiscal year ended December 31, 2022, will revise our reconciliation from Net Cash Provided
by Operating Activities to Adjusted EBITDA to clarify that the adjustment for Changes in operating assets and liabilities, net comprises
of changes in the following:

 ● Accounts
                                            receivable – oil, natural gas and natural gas liquids sales

 ● Accounts
                                            receivable – joint interest and other

 ● Accounts
                                            payable and accrued liabilities

 ● Prepaid