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CORRESP

 PRIVILEGED AND CONFIDENTIAL

August 13, 2021

 VIA EDGAR

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Energy & Transportation

 100 F
Street, N.E.

 Washington, DC 20549

Attention:      Sandra Wall

   Brad Skinner

Re:
 Contango Oil & Gas Company

Form 10-K for the Fiscal Year Ended December 31, 2020, Filed March 10, 2021 (File No. 001-16317)

 Ladies and Gentlemen:

On behalf of Contango Oil & Gas Company, a Texas corporation (the “Company”), set forth below are responses of the
Company to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) contained in your letter dated August 12, 2021 (the
“Comment Letter”) regarding the above-referenced Form 10-K for the Fiscal Year Ended December 31, 2020, File No. 001-16317 (the “2020
Annual Report”). Capitalized terms used herein and otherwise not defined herein shall have the meanings assigned to such terms in the 2020 Annual Report.

For your convenience, each response is prefaced by the exact text of the Staff’s corresponding comment in bold, italicized text. All
references to page numbers and captions correspond to the 2020 Annual Report unless otherwise specified.

 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.

 111 E. 5th Street  |  Suite 300  |  Fort Worth, Texas 76102

Office: 817.529.0059  |  Fax: 713.236.4424

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Energy &
Transportation

 August 13, 2021

 Page 2

 Response: William M. Cobb & Associates, Inc. has delivered a revised reserve
report as of December 31, 2020 addressing the foregoing comments, a copy of which is attached as Exhibit A hereto. This report has been revised to reflect disclosures to be included in corresponding applicable future reports to be filed by the
Company with the Commission.

 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 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 submit a revised reserve report which resolves these inconsistencies or tell us why a revision is not needed.”

Response: W.D. Von Gonten and Company has delivered a revised reserve report as of December 31, 2020 addressing the foregoing
comments, a copy of which is attached as Exhibit B hereto. This report has been revised to reflect disclosures to be included in corresponding applicable future reports to be filed by the Company with the Commission.

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Energy &
Transportation

 August 13, 2021

 Page 3

 Please direct any questions concerning this letter to the undersigned at (713)
236-7575 or JGrady@contango.com.

 Very truly yours,

 /s/ E. Joseph Grady

E. Joseph Grady

Senior Vice President and Chief Financial Officer

 cc: Hillary H. Holmes, Gibson, Dunn & Crutcher LLP

   Charles L. McLawhorn, Senior Vice President, General Counsel and Corporate Secretary

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Energy &
Transportation

 August 13, 2021

 Page 4

 Exhibit A

[Updated William M. Cobb & Associates, Inc. Report]

 WILLIAM M. COBB & ASSOCIATES, INC.

Worldwide Petroleum Consultants

 12770 Coit Road, Suite 907

 Dallas,
Texas

 (972) 385-0354

Fax: (972) 788-5165

E-Mail: office@wmcobb.com

 August 12, 2021

Mr. Chad Roller

 Contango Oil & Gas Company

717 Texas Avenue, Suite 2900

 Houston, TX 77002

Dear Mr. Roller:

 In accordance with your request, William
M. Cobb & Associates, Inc. (Cobb & Associates) has estimated the proved reserves and future income as of January 1, 2021, attributable to the interest of Contango Oil & Gas Company and its subsidiaries (Contango) in
certain oil and gas properties located in Oklahoma, Texas, Louisiana, state and federal waters of the Gulf of Mexico, Wyoming, Mississippi, and Kansas. This report was completed on February 25, 2021 and minor revisions to the wording were made
on July 29, 2021.

 Reserves presented in this report are classified as proved and are further categorized as proved developed producing (PDP), proved
non-producing (PNP), proved shut-in (PSI), and proved undeveloped (PUD). Table 1 summarizes our estimate of the proved oil and gas reserves and their pre-federal income tax value undiscounted and discounted at ten percent using SEC pricing.

 TABLE 1

 CONTANGO OIL AND GAS COMPANY

TOTAL PROVED RESERVES AND CASH FLOW SUMMARY

AS OF JANUARY 1, 2021

YEAR-END 2020 SEC PRICE

Net Reserves

Future Net Cash Flow

 Reserves

Category

Oil
(MBBL)

Gas
(MMCF)

NGL
(MBBL)

Undisc.
(M$)

Disc. 10%
(M$)

 PDP

7,163

82,257

6,562

158,852

111,943

 PNP

4

531

32

202

160

 PSI

0

0

0

0

0

 PUD

5,838

1,694

559

49,548

14,273

 TOTAL PROVED

13,004

84,482

7,154

208,602

126,376

 Mr. Chad Roller

August 12, 2021

 Page 2

 Values shown were determined utilizing constant oil and gas prices and well operating expenses. The
discounted present worth of future income values shown in Table 1 are not intended to represent an estimate of fair market value. These estimates were prepared in accordance with the definitions and regulations of the U.S. Securities and Exchange
Commission (SEC) and, with the exception of the exclusion of future income taxes, conform to the FASB Accounting Standards Certification Topic 932, Extraction Activities – Oil and Gas.

Oil and NGL volumes are expressed in thousands of stock tank barrels (MBBL). A stock tank barrel is equivalent to 42 United States gallons. Gas volumes are
expressed in millions of standard cubic feet (MMCF) as determined at 60o Fahrenheit and the legal pressure base for the specific location of the gas reserves.

Cobb & Associates reviewed 100 per cent of the properties included in this report. This report, which was prepared for Contango’s use in
filing with the SEC and will be filed with Contango’s Form 10-K for fiscal year ending December 31, 2020 (the “Form 10-K”) and covers
100 percent of the total company present value discounted at ten percent (PV10) presented in Contango’s Form 10-K. All assumptions, data, methods, and procedures considered necessary and appropriate
were used to prepare this report.

 DISCUSSION

The Contango properties are divided into five regions: Central Oklahoma, Offshore, Onshore, Western Anadarko, and West Texas. The Central Oklahoma and Western
Anadarko properties are located in Oklahoma and north west Texas and 47.5 and 12.5 percent, respectively, of the total proved discounted present value are attributable to these properties. These properties were acquired from White Star
Petroleum and Will Energy in late 2019. The onshore properties are located in Louisiana, Mississippi, east Texas, and Wyoming and make up 5.3 percent of the total proved discounted value. The offshore properties are located in Louisiana state
and federal waters of the Gulf of Mexico and contribute 7.5 percent of the total proved discounted value. The west Texas properties are located in Pecos County in the Delaware Basin and provide 27.2 percent of the total proved discounted
value.

 Reserve estimates were prepared using generally accepted petroleum engineering principles and practices. The method, or combination of methods,
utilized in the study of each property or reservoir included an assessment of the stage of reservoir development, quality of data, and length of production history. Geologic and engineering data was obtained from Contango, public sources, and the non-confidential files of Cobb & Associates.

 Performance data through December of 2020 was used to forecast
reserves for all producing properties where available. Reserve classification was based on the status of each well as of January 1, 2021 for operated wells, and on the most recently available information for
non-operated wells.

 For most regions in the report, the PDP reserve estimates were based on decline curve
analysis. Some of the properties have produced for only a short period of time and did not exhibit an identifiable performance decline trend. In these cases, reserve estimates were based primarily on geological interpretation, mapping, and analogy
to offset producers. Past performance, and offsetting performance data were used to estimate behind pipe and undeveloped reserves. Fields where additional analysis or methodology was used for the reserve assignments are discussed in more detail.
These fields include Eugene Island 11 and properties in west Texas.

 Mr. Chad Roller

August 12, 2021

 Page 3

 Offshore - Eugene Island 11

Eugene Island 11 is located in federal and Louisiana state waters of the Gulf of Mexico, at a water depth of approximately 13 feet. Production is primarily
from a single CibOp sand, the JRM-1 sand, at a depth of approximately 15,000 feet. The field was discovered in September, 2006 by the Contango Operators Dutch 1 well. Contango has since drilled four more
wells, the Dutch 2, 3, 4 and 5, on Federal acreage. The Dutch 5 well is depleted and is scheduled for abandonment in December 2021.

 Contango also has
properties in Louisiana state waters in this field. These properties are referred to as the Mary Rose prospect. Five Mary Rose wells have been drilled to date. Four Mary Rose wells, numbers 1 through 4, have produced from the main CibOp sand. The
Mary Rose 4 well is depleted and has been abandoned. The Mary Rose 3 is also depleted, with abandonment scheduled for December 2021.

 The Mary Rose 5 well
produced from a separate, and much smaller, CibOp reservoir that is now depleted. Abandonment of the Mary Rose 5 was completed in 2019.

 Proved reserves
for the Eugene Island 10 main CibOp sand are based on analysis of historical rate versus time decline curves and P/Z performance plots, supplemented by volumetric calculations of original-gas-in-place (OGIP) using all available well log and 3D seismic data. The reservoir has been effectively drilled to the lowest structural datum and no significant aquifer has been found.
Performance to date indicates a depletion drive system.

 All Dutch and Mary Rose wells now flow to compression on the ‘H’ platform, allowing for
a decrease in producing flowing tubing pressures. This two-stage compression lowers line pressure to approximately 200 psi. There are no remaining capital or startup costs for compression on the ‘H’
platform. Abandonment costs were provided by Contango and scheduled at the end-of-project life for all wells and the ‘H’ platform.

West Texas – Bullseye and North East Bullseye

During 2017, Contango embarked on a drilling program for Wolfcamp Shale wells in Pecos County, Texas. In the Bullseye area, 14 wells have been drilled and
completed and are carried as proved developed producing (PDP) in this report. In December 2019, Contango acquired additional acres and designated this as the north east Bullseye area. Four wells have been drilled and completed and are currently
producing as of January 1, 2021 in the north east Bullseye area.

 There are three prospective formations in the north east Bullseye area, from the
deepest to the shallowest, these are the Wolfcamp B, Wolfcamp A, and the 2nd Bone Springs. One bench of wells in the Wolfcamp B and the
2nd Bone Springs have been planned as well as two benches of wells in the Wolfcamp A.

 Traditional
decline curve analysis has difficulty predicting the well-to-well interactions between long horizontal wells in the shale plays. As a result, to improve the long-term
prediction of PUD reserves, advanced simulation software and automatic parameter variation within certain ranges based on the estimated range and uncertainty in the reservoir and completion properties in the area was used to develop probabilistic
history matches for the existing wells. The history matches were based on the optimal matches to oil, gas, and water production and bottom hole pressure data for each well.

 Mr. Chad Roller

August 12, 2021

 Page 4

 The reservoir properties from these matches were then used to study the optimal well spacing for the north
east Bullseye development. Based on the results from this study, the optimum well spacing was determined to be 1,100 ft in the Wolfcamp formation. With the available space in a typical unit with dimensions of one mile by two miles and the
1,100 ft well spacing there are space for five locations in the Wolfcamp A and four locations in the Wolfcamp B.

 The second part of the simulation study
assessed the well-to-well interactions in order to develop a type curve that accounted for these interactions. A model with an existing Wolfcamp A well and an
existing Wolfcamp B well was used for this evaluation. A large number of simulations were run with different reservoir properties to generate a probabilistic reserve distribution for the Wolfcamp PUD locations. These were then analyzed and
a P50 profile was generated for each location. These location profiles were then averaged to generate a type curve to be used for the Wolfcamp A and Wolfcamp B. Locations within the Contango five-year capital plan taking into account market
uncertainty were booked as PUD reserves in this report.

 OIL AND GAS PRICING

Projections of proved reserves contained in this report utilize constant product prices of $2.14 per MMBTU of gas and $39.57 per barrel of oil. These are the
average first-of-month prices for the prior 12-month period for Henry Hub gas and West Texas Intermediate (WTI) oil. Appropriate
oil and gas pricing differentials, residue gas shrink, NGL yields, and NGL pricing as a fraction of WTI were calculated for each field using 12 months of revenue data where available. After applying appropriate differentials for each property, the
weighted average realized product prices for 2021 were $36.74 per barrel of oil and $1.87 per MCF of gas, resulting in average 2021 differentials of negative $2.83 per barrel and negative $0.27 per MCF.

OPERATING COSTS

 Future operating costs for each
of the Contango wells are held constant at current values for the life of the property. These costs were calculated using 12-month lease operating expense (LOE) statements provided by Contango. In general, the
LOE statements for each of the properties were analyzed by field or production area. LOE data was available for most areas through the second quarter of 2020 for most areas. Each well was assigned a fixed monthly operating cost, variable costs for
oil and gas, and water handling costs per produced barrel of water. Oil, gas, and NGL transportation and processing fees were also assigned to each well by product purchaser using net revenue data in a similar manner that product differentials were
determined.

 LOE data for the Eugene Island 11 properties was analyzed at a well level. Fixed operating costs