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SEC Comment Letter for DEVON ENERGY (DVN) — Dec 16, 2014

DEVON ENERGY CORP/DE (DVN) (CIK 0001090012)
Date: Dec. 16, 2014 · CIK: 0001090012 · Accession: 0000000000-14-064965

Regulatory Compliance Financial Reporting Risk Disclosure

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Confidence
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Reasoning

Referenced dates: November 17, 2014

Date
December 16, 2014
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
DEVON ENERGY CORP/DE (DVN) (CIK 0001090012)

Letter

December 16, 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, 2013 Filed February 28, 2014 File No. 1 -32318

Dear Mr. Mitchell:

We refer you to our comment letter dated November 17, 2014, regarding countries that have been identified as state sponsors of terrorism . We have completed our review of this subject matter. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
December 16, 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, 2013
  Filed February 28, 2014
  File No. 1 -32318

Dear Mr. Mitchell:

We refer you to our comment letter dated November 17, 2014, regarding countries that
have been identified as state sponsors of terrorism .  We have completed our review of this
subject matter.  We remind you that our comments or changes to disclosure in response to our
comments do not foreclose the Commission from taking any action with respect to the company
or 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.
We urge all persons who are responsible for the accuracy and adequacy of  the disclosure in the
filing to be certain that the filing includes the information the Securities Exchange Act of 1934
and all applicable rules require.

         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