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SEC Company Response from DEVON ENERGY (DVN) — May 31, 2006

DEVON ENERGY CORP/DE (DVN) (CIK 0001090012)
Date: May 31, 2006 · CIK: 0001090012 · Accession: 0000950134-06-010803

Financial Reporting Regulatory Compliance Internal Controls

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Referenced dates: May 12, 2006

Date
May 30, 2006
Author
/s/ Danny J. Heatly
Form
CORRESP
Company
DEVON ENERGY CORP/DE (DVN) (CIK 0001090012)

Letter

Securities and Exchange Commission Division of Corporation Finance — Mail Stop 7010 Attention: Mr. Gary Newberry Devon Energy Corporation Form 10-K for the Fiscal Year ended December 31, 2005 Filed March 3, 2006 File No. 1-32318

Dear Mr. Newberry:

We are in receipt of your letter dated May 12, 2006, containing comments of your review of the above-referenced Form 10-K for the Fiscal Year ended December 31, 2005. In such letter, you requested that we amend our filing and respond to comments within 10 business days or advise when a response would be provided. Due to our apparent mishandling of your letter, Mr. Brian Jennings, Chief Financial Officer, did not receive the letter until today, May 30, 2006.

Therefore, we request an extension of the original response time, so that our response is due within 10 business days from today, May 30, 2006.

Thank you for your consideration of this request, and we apologize for any inconvenience this may cause.

Sincerely,
/s/ Danny J. Heatly

Show Raw Text
CORRESP
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corresp

[DEVON LOGO]

Devon Energy Corporation

20 North Broadway

Oklahoma City, Oklahoma 73102-8260

Danny J. Heatly

Vice President — Accounting

(405) 552-4702

May 30, 2006

Securities and Exchange Commission

Division of Corporation Finance — Mail Stop 7010

100 F Street, N.E.

Washington, D.C. 20549-7010

Attention: Mr. Gary Newberry

    Re:

    Devon Energy Corporation

    Form 10-K for the Fiscal Year ended December 31, 2005

    Filed March 3, 2006

    File No. 1-32318

Dear Mr. Newberry:

We are in receipt of your letter dated May 12, 2006, containing comments of your review of the
above-referenced Form 10-K for the Fiscal Year ended December 31, 2005. In such letter, you
requested that we amend our filing and respond to comments within 10 business days or advise when a
response would be provided. Due to our apparent mishandling of your letter, Mr. Brian Jennings,
Chief Financial Officer, did not receive the letter until today, May 30, 2006.

Therefore, we request an extension of the original response time, so that our response is due
within 10 business days from today, May 30, 2006.

Thank you for your consideration of this request, and we apologize for any inconvenience this may
cause.

Sincerely,

/s/ Danny J. Heatly

Danny J. Heatly

Vice President — Accounting

    cc:

    H. Roger Schwall, Assistant Director — SEC

    Brian J. Jennings, CFO — Devon