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August 12, 2021
E. Joseph Grady
Chief Financial Officer and Chief Accounting Officer
CONTANGO OIL & GAS CO
717 Texas Ave., Suite 2900
Houston, Texas 77002
Re:CONTANGO OIL & GAS CO
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed March 10, 2021
File No. 001-16317
Dear Mr. Grady:
            We have reviewed your August 5, 2021 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our July 27,
2021 letter.
Form 10-K for the Fiscal Year Ended December 31, 2020
Exhibit Number 99.1 Report of William M. Cobb & Associates, Inc., page 80
1.We have read your response to prior comment 12 and note the revised reserve report
prepared by William M. Cobb has removed the references to Exhibit A and Exhibit B but
retained the description of these items which are not provided within the reserve report or
within your 10-K disclosure. Please obtain and submit a revised reserve report which
includes this information or remove these references.
Exhibit Number 99.2 Report of W.D. Von Gonten and Company, page 80
2.We have read your response to prior comment 8 and note we are unable to find the revised
disclosure or the reason why a revision is not needed. We are reissuing our original
comment, "Disclosure of the "Reporting Requirements" provided on page 2 references the

 FirstName LastNameE. Joseph Grady
 Comapany NameCONTANGO OIL & GAS CO
 August 12, 2021 Page 2
 FirstName LastName
E. Joseph Grady
CONTANGO OIL & GAS CO
August 12, 2021
Page 2
SPE PRMS and Rule 4-10 of Regulation S-X but appears to indicate that the estimated
proved reserves shown in the report were prepared in conformance with the SPE
definitions. Furthermore, the disclosure refers to regulations and standards under Item 102
of Regulation S-K and the Financial Accounting Standards Board (FASB) Statement No.
69 which have been updated pursuant to the Modernization of Oil and Gas
Reporting; Final Rule. Please obtain and submitt a revised reserve report which resolves
these inconsistencies or tell us why a revision is not needed."
            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.
            You may contact Sandra Wall, Petroleum Engineer, at (202) 551-4727 if you have
questions regarding the engineering comments.  Please contact Brad Skinner, Office Chief, at
(202) 551-3489 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation