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June 21, 2021

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F. Street N.E.

Washington, D.C. 20549

 Attn: Joanna Lam

Brian McAllister

 Re: Goodrich Petroleum Corporation

Form 10-K for the Fiscal Year Ended December 31,
2020

Form 8-K filed May 6, 2021

File No. 001-12719

Ladies and Gentleman:

We refer to your letter dated May 25, 2021 commenting
on the disclosures contained in Goodrich Petroleum Corporation’s (“our” or “we”) Current Report on Form
8-K filed on May 6, 2021. For your convenience, we have repeated the Staff’s comment below in italics.

Form 8-K filed May 6, 2021

Exhibit 99.1, page 1

 1. Your disclosures under the headings Quarter Highlights and Financial Results frequently disclose
non-GAAP measures that either precede or exclude a discussion and analysis of the most directly comparable GAAP measures. Please revise
disclosures in the quarterly financial results of your press release to provide a discussion and analysis of the most comparable GAAP
measures in a location with equal or greater prominence to each instance that a non-GAAP measure is disclosed. See Item 10(e)(1)(i)(A)
of Regulation S-K and Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.

We acknowledge the Staff’s comment
and respectfully advise the Staff that we have revised the May 6, 2021 press release to address the Staff’s comment. Such revised
press release, in redlined form, is attached to this correspondence as Appendix A. In addition, we undertake to include similar,
corresponding changes in future press releases, beginning with the press release containing our quarterly financial results for the quarter
ended June 30, 2021.

Please contact Michael S.
Telle of Vinson & Elkins L.L.P. at (713) 758-2350 or me at (832) 399-3173 with any questions with respect to the foregoing or if any
additional supplemental information is required by the Staff.

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    Very truly yours,

    GOODRICH PETROLEUM CORPORATION

    By:
    /s/ Michael J. Killelea

    Name:
    Michael J. Killelea

    Title:
    Executive Vice President, General Counsel and Corporate Secretary

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Appendix A

Exhibit 99.1

Goodrich Petroleum Announces First Quarter
2021 Financial Results

HOUSTON, May 6, 2021 /PRNewswire/ -- Goodrich Petroleum Corporation
(NYSE American: GDP) (the "Company") today announced financial results for the first quarter ended March 31, 2021.

QUARTER HIGHLIGHTS

Net
income was $4.5 million in the quarter ($0.34 per basic and $0.30 per fully diluted share).

Adjusted net income (net income prior to change in fair
value of derivatives not designated as hedges) was $7.1 million for the quarter. Net income was $4.5
million in the quarter ($0.34 per basic and $0.30 per fully diluted share).

Adjusted EBITDA was $20.3 million in the quarter.

Net cash provided by operating activities
was $21.1 million in the quarter.

Discretionary cash flow ("DCF"), defined as
net cash provided by operating activities before changes in working capital, was $19.6 million in the quarter.

Production totaled 11.2 Bcfe in the quarter, or an average
of approximately 125,000 Mcfe per day. The Company completed 9 gross (3.3 net) wells in the quarter. Production for the quarter was negatively
impacted by weather. The Company is guiding to an average of 150,000-160,000 Mcfe per day for the second quarter, and maintains its guidance
for the year of an average of 160,000 Mcfe per day.

Per
unit expense was $1.89 per Mcfe for the quarter.

Cash Expenses:
Per unit cash expense was $1.07 per Mcfe for the quarter, broken out as follows:

 · Lease operating expense ("LOE") was $0.28 per Mcfe, which included
workover expense of $0.04 per Mcfe;

 · Production and other taxes were $0.06 per Mcfe, which included $0.04 per Mcfe
for production taxes and $0.02 per Mcfe for ad valorem taxes;

 · Transportation and processing expense was $0.36 per Mcfe;

 · General and Administrative ("G&A") expense payable in cash
was $0.29 per Mcfe (which excluded $0.03 per Mcfe of share based compensation
expense); and

 · Cash
Interest expense was $0.08 per Mcfe (which excluded $0.09 per Mcfe of non-cash
interest expense).

Return on Invested Capital ("ROIC"), defined
as trailing twelve month Adjusted EBITDA divided by total assets less current liabilities, was 38% at quarter-end.

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Cash Margin was $1.70 per Mcfe (61%), comprised of a
net realized price including hedges of $2.77 per Mcfe less per unit cash expenses detailed above of $1.07 per Mcfe.

Well Result: The Company has recently completed its
Lattin 3&34 No. 1 (76% WI) well in a new area northeast of its Bethany-Longstreet field in DeSoto and Caddo Parishes, Louisiana. The
well, which has a usable lateral length of 9,934 feet had a 24-hour production rate of approximately 35,000 Mcfe per day.

Please
see the disclosures and tables at the end of this press
release for a discussion of the non-US GAAP measures presented
above and in the discussion below and a reconciliation of such measures to the most
directly comparable US GAAP financial measure.

THE COMPANY HAS POSTED A NEW PRESENTATION ON ITS WEBSITE
THAT INVESTORS CAN ACCESS AT: http://goodrichpetroleumcorp.investorroom.com/presentations. The slides will be reviewed on the earnings
conference call scheduled for today at 10:00 am central time.

To access the conference call, domestic participants should
dial as follows:

    PARTICIPANT DIAL IN (TOLL FREE):
    1-888-317-6003

    PARTICIPANT INTERNATIONAL DIAL IN:
    1-412-317-6061

    Canada Toll Free
    1-866-284-3684

    Participant Elite Entry Number:  0945541

    Participants will need this Elite Entry number in order to
    join the conference.  The Company encourages participants to dial in 10-15 minutes early to join the conference.

    Participants may also access the live audio webcast of the
    conference call through the following web link: https://www.webcaster4.com/Webcast/Page/937/40711 or by accessing the webcast through
    the investor relations section of the Company's website.

FINANCIAL RESULTS

NET INCOME

Net
income was $4.5 million in the quarter, or $0.34 per basic and $0.30 per fully diluted share, versus net income of $3.0 million, or $0.24
per basic and $0.22 per fully diluted share, in the prior year period. Adjusted net income was $7.1 million in the quarter.

CASH FLOW

Net cash
provided by operating activities was $4.5 million in the quarter versus $3.0 million in the prior year period. Adjusted EBITDA
was $20.3 million in the quarter and discretionary cash flow ("DCF"), defined as net cash provided by operating activities before
changes in working capital, was $19.6 million in the quarter versus Adjusted EBITDA of $16.6 million and DCF of $15.4 million in the prior
year period.

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(See accompanying tables
at the end of this press release that reconcile Adjusted EBITDA and DCF, each of which are non-US GAAP
financial measures, to their most directly comparable US GAAP financial measure.)

NET INCOME

Adjusted net income was $7.1 million in the quarter.
Net income was $4.5 million in the quarter, or $0.34 per basic and $0.30 per fully diluted share, versus net income of $3.0 million, or
$0.24 per basic and $0.22 per fully diluted share, in the prior year period.

(See accompanying tables at the end of this press
release that reconciles adjusted net income, which is a non-US GAAP financial measure, to its most directly comparable US GAAP financial
measure.)

PRODUCTION

Production totaled approximately 11.2 Bcfe in the quarter,
or an average of approximately 125,000 Mcfe (98% natural gas) per day, versus 12.5 Bcfe, or an average daily production of approximately
137,000 Mcfe (98% natural gas) per day, in the prior year period.

REVENUES

Oil and
natural gas revenues were $31.9 million and oil and natural gas revenues adjusted for cash settled derivatives were $31.2 million.
Oil In the prior year period,
oil and natural gas revenues prior to net cash payments of were
$0.7 23.0
million for settlement of derivatives was $31.9 million. Oil and and
oil and natural gas revenues including cash settled derivatives were $29.0 million in the
prior year period. Average realized price per unit was $2.84 per Mcfe ($2.72 per Mcf of gas and $57.88 per barrel of oil)
in the quarter, versus $1.84 per Mcfe in the prior year period ($1.73 per Mcf of gas and $47.64 per barrel of oil). Average realized price
per unit when incorporating the Company’s settled derivatives for the quarter was $2.77 per Mcfe.

(See accompanying table at the end of this press
release that reconciles oil and natural gas revenues adjusted for cash settled derivatives, which is a non-US GAAP financial measure,
to its most directly comparable US GAAP financial measure.)

OPERATING EXPENSES

Lease operating expense ("LOE") was $3.2 million
in the quarter, or $0.28 per Mcfe, which included $0.5 million, or $0.04 per Mcfe, for workovers. LOE was $3.3 million, or $0.27 per Mcfe,
in the prior year period, which included $0.5 million, or $0.04 per Mcfe, for workovers.

Production and other taxes were $0.6 million in the
quarter, or $0.06 per Mcfe, versus $0.9 million, or $0.07 per Mcfe, in the prior year period.

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Transportation and processing expense was $4.0 million
in the quarter, or $0.36 per Mcfe, versus $4.9 million, or $0.39 per Mcfe, in the prior year period.

Depreciation, depletion and amortization ("DD&A")
expense was $10.1 million in the quarter, or $0.90 per Mcfe, versus $13.3 million, or $1.06 per Mcfe, in the prior year period.

General and administrative expense ("G&A")
was $3.5 million in the quarter, or $0.32 per Mcfe, versus $4.9 million, or $0.39 per Mcfe, in the prior year period. G&A expense
payable in cash was $3.2 million, or $0.29 per Mcfe, versus $3.8 million, or $0.30 per Mcfe, in the prior year period.

(See accompanying table at the end of this press
release that reconciles G&A expense payable in cash, which is a non-US GAAP financial measure, to its most directly comparable US
GAAP financial measure.)

OPERATING INCOME/LOSS

Operating
income totaled $10.6 million in the quarter. Adjusted
operating income was $9.9 million for the quarter, which included a $0.7 million loss on cash settled derivatives. Operating
income, defined as revenues minus operating expenses, totaled $10.6 million in the
quarter. Adjusted operating income was $1.7 million in In
the prior year period, which included $6.0 million received for cash settled derivatives. The
the Company had an operating loss of $4.3 million in
the prior year period.and had adjusted operating income of
$1.7, which included $6.0 million received for cash settled derivatives.

(See accompanying table at the end of this press
release that reconciles adjusted operating income, which is a non-US GAAP financial measure, to its most directly comparable US GAAP financial
measure.)

INTEREST EXPENSE

Interest expense totaled $1.9 million in the quarter, which
included interest payable in cash of $0.9 million incurred on the credit facility and non-cash interest of $1.0 million incurred primarily
on the Company's second lien notes, which included $0.6 million paid in-kind interest and $0.4 million amortization of debt discount and
issuance costs. Interest expense for the prior year period was $2.0 million, which included interest payable in cash of $1.2 million incurred
on the credit facility and non-cash interest of $0.8 million incurred primarily on the Company's second lien notes, which included $0.4
million paid in-kind interest and $0.4 million amortization of debt discount and issuance costs.

(See accompanying table at the end of this press
release that reconciles interest payable in cash, which is a non-US GAAP financial measure, to its most directly comparable US GAAP financial
measure.)

CAPITAL EXPENDITURES

Capital expenditures totaled $29.3 million in the quarter,
of which a majority was spent on drilling and completion costs, versus $18.4 million in the prior year period, of which a majority was
spent on drilling and completion costs. The Company conducted drilling and completion operations on 14 gross (6.5 net) wells and added
9 gross (3.3 net) wells to production in the quarter. The Company reaffirms its full year preliminary budget of $75 - $85 million and
the Board of Directors will review the remaining 2021 capital expenditure budget quarterly and adjust, if necessary, based on commodity
prices and the goal of free cash flow generation from moderate growth in volumes and a further reduction in per unit costs.

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BALANCE SHEET

The Company exited the quarter with $1.2 million of cash, $87.4
million outstanding under the Company's credit facility, and total principal debt outstanding, including the credit facility and second
lien notes, of $117.8 million.

CRUDE OIL AND NATURAL GAS DERIVATIVES

The Company had a loss of $3.3 million on its derivatives not
designated as hedges in the quarter, which was comprised of a loss of $0.7 million on cash settlements and a $2.6 million loss representing
the change of the fair value of our open natural gas and oil derivative contracts, versus a gain of $9.1 million on its derivatives not
designated as hedges in the prior year period, which was comprised of a gain of $6.0 million on cash settlements and a $3.1 million gain
representing the change in fair value of our open natural gas and oil derivative contracts.

RECENT DEVELOPMENTS

SPRING REDETERMINATION UNDER SENIOR CREDIT FACILITY

In conjunction with its spring redetermination under its reserve
based lending facility, the Company and participating banks have reaffirmed the existing borrowing base of $120 million.

OTHER INFORMATION

Certain
statements in this news release regarding future expectations and plans for future activities may be regarded as “forward looking
statements” within the meaning of the Securities Litigation Reform Act. They are subject to various risks, such as financial market
conditions, changes in commodities prices and costs of drilling and completion, operating hazards, drilling risks, and the inherent uncertainties
in interpreting engineering data relating to underground accumulations of oil and gas, as well as other risks discussed in detail in the
Company’s Annual Report on Form 10-K for the year ended December 31, 2020 and other subsequent filings with the Securities and Exchange
Commission. Although the Company believes that the expectations reflected in such forward-looking statements are reasonable, it can give
no assurance that such expectations will prove to be correct.

Unless
otherwise stated, oil production volumes include condensate.

Goodrich
Petroleum is an independent oil and natural gas exploration and production company listed on the NYSE American under the symbol “GDP”.

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NON-US
GAAP INFORMATION

In this press release, the Company refers to several non-US
GAAP financial measures, including Adjusted EBITDA, DCF, Return on Invested Capital ("ROIC"),
cash margin, oil and natural gas revenues adjusted for cash settled derivatives, adjusted net income, adjusted operating income
(loss), G&A expense payable in cash and interest payable in cash. Management believes Adjusted EBITDA, DCF and ROIC are good financial
indicators of the Company's performance and ability to internally generate operating funds. Adjusted EBITDA and adjusted net income should
not be considered an alternative to net income (loss) applicable to common stock, as defined by US GAAP. DCF should not be considered
an alternative to net cash provided by operating activities, as defined by US GAAP. Oil and natural gas revenues adjusted for cash settled
derivatives should not be considered an alternative for oil and natural gas revenues, as defined by US GAAP. Adjusted operating income
(loss) should not be considered an alternative to operating income (loss), as defined