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    Devon Energy Corporation

20 North Broadway

Oklahoma City, OK 73102-8260

    405 552 4702 Phone

405 552 7692 Fax

danny.heatly@dvn.com

August 18, 2010

Via EDGAR and Facsimile No. 703 813 6982

Attention: Mr. Bob Carroll, Division of Corporation Finance

H. Roger Schwall

Assistant Director

U.S. Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549-7010

    Re:

    Devon Energy Corporation

Form 10-K for the Fiscal Year Ended December 31, 2009

Filed February 25, 2010

Response Letter Dated June 25, 2010

File No. 1-32318

Dear Mr. Schwall:

This letter responds to the staff’s comment letter dated August 4, 2010, regarding Devon Energy
Corporation’s Form 10-K for the year ended December 31, 2009, filed February 25, 2010 (File No.
1-32318). Devon’s responses to the staff’s comments are set forth below:

Exhibits 99.1, 99.2 and 99.3

SEC Comment

    1.

    We direct your attention to prior comment one in our letter dated April 8, 2010. Please
obtain and file revised reports that comply with such comment.

Response

We filed on this date a Form 10-K/A that includes revised Exhibits 99.1, 99.2 and 99.3. The
revised exhibits do not contain the previous language that suggested a limit on potential investor
reliance. Language that clarifies the reports are intended for public disclosure is included in
the third and fourth paragraphs of page four in Exhibit 99.1, the first and second paragraphs of
page nine in Exhibit 99.2, and the last paragraph of page two and the first paragraph of page three
in Exhibit 99.3.

SEC Comment

    2.

    We note your response to prior comment six in our letter dated June 11, 2010. We do not
agree with your position that “...inclusion of weighted average prices in the third-party
reports would have no relevance.” Assuming that the third-party reports cover a significant
portion of your properties (92% in this case), comparison between weighted average prices in
the reports and benchmark prices can be valuable information for the public. It is the
staff’s position that

    U.S. Securities and Exchange Commission

    page 2

    August 18, 2010

    the weighted average prices used in the third-party report is a primary economic assumption
under Item 1202(a)(8)(v) of Regulation S-K. Please revise the report accordingly.

Response

Exhibits 99.1, 99.2 and 99.3 to the Form 10-K/A filed on this date disclose the relevant benchmark
prices and the weighted average prices. Such prices are included in the first paragraph of page
three in Exhibit 99.1, the table on page seven in Exhibit 99.2, and the table on page 16 of the
“Evaluation Procedure — Definitions and Methodology” section in Exhibit 99.3.

SEC Comment

    3.

    We note that the third party report by LaRoche discloses that your estimates are “in the
aggregate reasonable” but there is no statement that the third party’s estimates and yours are
within 10% of each other. Reasonable agreement is defined by Society of Petroleum Engineers
as within 10%. Since LaRoche has stated that it subscribes to the standards of the SPE, such
a statement is appropriate. Please amend your document to include, if true, this statement.

Response

Exhibit 99.1 to the Form 10-K/A filed on this date includes the statement that LaRoche’s estimates
and Devon’s estimates are within 10% of each other. This statement is included in the fourth
paragraph of page two in Exhibit 99.1.

SEC Comment

    4.

    We note the statement “Devon’s estimates of proved oil and gas reserves and future cash
flow...are in the aggregate reasonable and have been prepared in accordance with generally
accepted petroleum engineering and evaluation principles.” While we understand that there are
fundamentals of physics, mathematics and economics that are applied in the estimation of
reserves, we are not aware of an official industry compilation of such “generally accepted
petroleum engineering and evaluation principles.” With a view toward possible disclosure,
please explain to us the basis for concluding that such principles have been sufficiently
established so as to judge that the reserve information has been prepared in conformity with
such principles. Refer us to a compilation of these principles.

Response

The quoted passage from Exhibit 99.1 of our Form 10-K was originally derived from Exhibit “A” of
the SPE document titled “Standards Pertaining to the Estimating and Auditing of Oil and Gas
Reserves Information” (last updated on February 19, 2007).
Although Devon utilizes a multitude of references in the compilation of reserves estimates, there
is no singular list of “principles” that can be referenced. Consequently, the language in the
fourth paragraph of page two in Exhibit 99.1 to the Form 10-K/A filed on this date has been
modified as follows:

    U.S. Securities and Exchange Commission

    page 3

    August 18, 2010

    “Devon’s estimates of proved oil and gas reserves and future cash flow...are in the
aggregate reasonable, are within 10 percent of our numbers and have been prepared in
accordance with generally accepted petroleum engineering and evaluation methods and
procedures.”

In connection with the above responses to the staff’s comments, Devon acknowledges that:

    •

    Devon is responsible for the adequacy and accuracy of the disclosure in the
filings;

    •

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

    •

    Devon 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.

Sincerely,

    /s/  Danny J. Heatly

    Danny J. Heatly

    Senior Vice President — Accounting and

Chief Accounting Officer