SecProbe.io

November 17, 2014

Via E -mail
Thomas L. Mitchell
Executive Vice President  and Chief Financial  Officer
Devon Energy Corporation
333 West Sheridan Avenue
Oklahoma City, OK 73102

 Re: Devon Energy Corporation
  Form 10 -K for Fiscal Year Ended December 31, 201 3
  Filed February 28, 2014
  File No. 1 -32318

Dear Mr. Mitchell :

We have limited our review of your filing to your contacts with countries that have been
identified  as state sponsors of terrorism, and we have the following comment .  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our comment  we ask you to provide us with inform ation so we may better
understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comment  applies to your facts and circumstances, please tell us why in your
response.

After reviewing the information you provide in response to th is comment , we may have
additional comments.

General

1. On pages 7, 37, and elsewhere in the 10 -K you refer to your joi nt venture with Sinopec
Corporation.  You state on page 40 that the joint venture had remaining commitments at
the end of 2013.  The 20 -F filed April 28, 2014 by China Petroleum & Chemical
Corporation (“CPCC”) indicates that CPCC is also known as “Sinopec Corp.”  We are
aware of recent state government and university divestment or similar initiatives
regarding CPCC due to its contacts with Iran and Sudan.  Iran and Sudan are designated
by the State Department as state sponsors of terrorism, and are subject to U.S. economic
sanctions and export controls.  Please discuss for us the potential for your relationship
with Sinopec to have an adverse impact upon your reputation and share value.

Thomas L. Mitchell
Devon Energy Corporation
November 17, 2014
Page 2

 We urge all persons who are responsible  for the accuracy and adequacy of the di sclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to the company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and ac curacy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in  any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Daniel Leslie, Staff Attorney, at (202) 551 -3876  or me at (202) 551 -3470
if you have any questions about the comment  or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye , Chief
         Office of Global Security Risk

cc:  Roger Schwall
  Assistant Director
 Division of Corporation Finance

 Jeremy Humphers
 Senior Vice President and Chief Accounting Officer
 Devon Energy Corporation