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SEC Comment Letter for DEVON ENERGY (DVN) — Mar 18, 2008

DEVON ENERGY CORP/DE (DVN) (CIK 0001090012)
Date: March 18, 2008 · CIK: 0001090012 · Accession: 0000000000-08-014201

Regulatory Compliance Financial Reporting Related Party / Governance

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File numbers found in text: 001-32318

Date
February 21, 2008
Author
Carmen Moncada-Terry
Form
UPLOAD
Company
DEVON ENERGY CORP/DE (DVN) (CIK 0001090012)

Letter

February 21, 2008 Mail Stop 7010 By U.S. Mail and facsimile to (405)552-8171

J. Larry Nichols Chairman and Chief Executive Officer 20 N Broadway Suite 1500 Oklahoma City, Oklahoma 73102 Re: Devon Energy Corporation Definitive Proxy Statement on Schedule 14A Filed April 27, 2007 File No. 001-32318 Dear Mr. Nichols: We have completed our review of your executive compensation and related disclosure, and we have no further comments at this time.

Please note that the company is responsib le for the adequacy and accuracy of the disclosure in its filing. We are not approving any proposed disclosure you may have included in your response letters or any disclosure you includ e in your future filings in response to our comments.

If you have any further questions regardi ng our review of your filing, please call me at (202) 551-3687. S i n c e r e l y , C a r m e n M o n c a d a - T e r r y A t t o r n e y A d v i s o r

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February 21, 2008 Mail Stop 7010
By U.S. Mail and facsimile to (405)552-8171

J. Larry Nichols Chairman and Chief Executive Officer 20 N Broadway Suite 1500 Oklahoma City, Oklahoma 73102
 Re:  Devon Energy Corporation  Definitive Proxy Statement on Schedule 14A  Filed April 27, 2007
File No. 001-32318
  Dear Mr. Nichols:
 We have completed our review of your executive compensation and related
disclosure, and we have no further comments at this time.

 Please note that the company is responsib le for the adequacy and accuracy of the
disclosure in its filing.  We  are not approving any proposed  disclosure you may have
included in your response letters  or any disclosure you includ e in your future filings in
response to our comments.

If you have any further questions regardi ng our review of your filing, please call
me at (202) 551-3687.           S i n c e r e l y ,            C a r m e n  M o n c a d a - T e r r y           A t t o r n e y  A d v i s o r