SEC Company Response from SM Energy (SM) — Dec 17, 2025
SM Energy Co
Date: Dec. 17, 2025 · CIK: 0000893538 · Accession: 0001104659-25-122203
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-291956
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation Washington, D.C. 20549-3561 Re: SM Energy Company Registration Statement on Form S-4, as amended File No. 333-291956
Dear Ms. Brown:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Act"), SM Energy Company (the "Company") hereby requests acceleration of the effective date of the above-referenced Registration Statement to 4:00 p.m., Eastern Time, on December 19, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Gibson, Dunn & Crutcher LLP, requests by telephone that such Registration Statement be declared effective. In making this acceleration request, the Company acknowledges that it is aware of its obligations under the Act.
Please contact Robyn E. Zolman of Gibson, Dunn & Crutcher LLP by telephone at (303) 298-5740 or via email at RZolman@gibsondunn.com as soon as the Registration Statement has been declared effective, or if you have any other questions regarding this matter. We also respectfully request that a copy of the written order from the Commission verifying the effective time of such Registration Statement be sent to Ms. Zolman via email at RZolman@gibsondunn.com.
Sincerely,
SM ENERGY COMPANY
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CORRESP 1 filename1.htm SM Energy Company 1700 Lincoln Street, Suite 3200 Denver, Colorado 80203 December 17, 2025 VIA EDGAR Cheryl Brown Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation 100 F Street, NE Washington, D.C. 20549-3561 Re: SM Energy Company Registration Statement on Form S-4, as amended File No. 333-291956 Dear Ms. Brown: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Act"), SM Energy Company (the "Company") hereby requests acceleration of the effective date of the above-referenced Registration Statement to 4:00 p.m., Eastern Time, on December 19, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Gibson, Dunn & Crutcher LLP, requests by telephone that such Registration Statement be declared effective. In making this acceleration request, the Company acknowledges that it is aware of its obligations under the Act. Please contact Robyn E. Zolman of Gibson, Dunn & Crutcher LLP by telephone at (303) 298-5740 or via email at RZolman@gibsondunn.com as soon as the Registration Statement has been declared effective, or if you have any other questions regarding this matter. We also respectfully request that a copy of the written order from the Commission verifying the effective time of such Registration Statement be sent to Ms. Zolman via email at RZolman@gibsondunn.com. Sincerely, SM ENERGY COMPANY /s/ James Lebeck James Lebeck Executive Vice President – Corporate Development and General Counsel cc: Robyn E. Zolman, Gibson, Dunn & Crutcher LLP