SecProbe.io

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      September 17, 2007

Via U.S. Mail and Facsimile

James J. Mulva
Chief Executive Officer
ConocoPhillips
600 North Dairy Ashford
Houston, TX 77079

RE:		ConocoPhillips
		Form 10-K for the fiscal year ended December 31, 2006
		Response letters dated April 12, 2007, June 7, 2007 and
July 13, 2007
		File No. 1-32395

Dear Mr. Mulva:

      We have limited our review of your Form 10-K for the fiscal
year ended December 31, 2006, and response letters, to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism.  Our review with respect to this
issue
does not preclude further review by the Assistant Director group
with
respect to other issues.  At this juncture, we are asking you to
provide us with supplemental information, so that we may better
understand your disclosure.  Please be as detailed as necessary in
your response. After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General -

1. We note your responses of June 7 and July 13, 2007.  To avoid
any
confusion in light of your previous disclosure regarding
termination
of your operations in Syria, and given the investor sentiment
evidenced by certain state legislative and other initiatives
regarding investment in companies that have business contacts with
countries identified as state sponsors of terrorism, it appears to
the staff that it would be appropriate for you to include in
future
filings information regarding your purchases from the Syrian
government and entities controlled by the Syrian government,
including the approximate dollar amounts of such purchases.  We
note
in this regard, among other investor actions, that Arizona and
Louisiana have adopted legislation requiring their state
retirement
systems to prepare reports regarding state pension fund assets
invested in, and/or permitting divestment of state pension fund
assets from, companies that do business with countries identified
as
state sponsors of terrorism.  The Missouri Investment Trust has
established an equity fund for the investment of certain state-
held
monies that screens out stocks of companies that do business with
U.S.-designated state sponsors of terrorism.  Similarly, Vermont`s
Pension Investment Committee has adopted a resolution restricting
investments in companies and governments linked to terrorist
activities.

2. Please provide the staff with draft disclosure language prior
to
filing.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please submit your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  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 connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company 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

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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	John A. Carrig
		Chief Financial Officer
	ConocoPhillips

		Roger Schwall
		Division of Corporation Finance
James J. Mulva
ConocoPhillips
September 17, 2007
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

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