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CORRESP
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 ConocoPhillips Company
 925 N. Eldridge Parkway
 Houston, TX 77079

 May 8, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: ConocoPhillips and ConocoPhillips Company
Registration Statement on Form S-4
Filed on May 8, 2025

 Ladies and Gentlemen:

 Reference is made to the above-referenced Registration Statement on
Form S-4 (the " Registration Statement "), filed by ConocoPhillips Company (the " Company ") and
ConocoPhillips (the " Guarantor ") with the U.S. Securities and Exchange Commission under the U.S. Securities Act of
1933, as amended (the " Act "). The Registration Statement registers $227,925,000 aggregate principal amount of the
Company's 4.400% Notes due 2027, $58,635,000 aggregate principal amount of the Company's 5.300% Notes due 2029, $102,042,000
aggregate principal amount of the Company's 6.800% Notes due 2032, $63,047,000 aggregate principal amount of the Company's
5.700% Notes due 2034, $259,050,000 aggregate principal amount of the Company's 6.600% Notes due 2037, and $151,419,000 aggregate
principal amount of the Company's 5.200% Notes due 2045, each of which is guaranteed by the Guarantor (collectively, the " Registered
Notes "), to be exchanged for an equal aggregate principal amount of the respective series of the Company's unregistered
4.400% Notes due 2027, 5.300% Notes due 2029, 6.800% Notes due 2032, 5.700% Notes due 2034, 6.600% Notes due 2037, and 5.200% Notes due
2045, each of which is guaranteed by the Guarantor (collectively, the " Restricted Notes ") (such exchange offers, the
 " Exchange Offers "). The Company is registering the Exchange Offers in reliance on the position of the staff of the
U.S. Securities and Exchange Commission (the " Staff ") enunciated in Exxon Capital Holdings Corporation (available
May 13, 1988), Morgan Stanley & Co. Incorporated (available June 5, 1991) and Shearman & Sterling
(available July 2, 1993).

 This will confirm that neither the Company nor the Guarantor has entered
into any arrangement or understanding with any person to distribute the Registered Notes and, to the best of the Company's and the
Guarantor's information and belief, each person participating in the Exchange Offers is acquiring the Registered Notes in its ordinary
course of business and has no arrangement or understanding with any person to participate in the distribution of the Registered Notes.
In this regard, the Company and the Guarantor will make each person participating in the Exchange Offers aware (through the Exchange Offer
prospectus) that if the Exchange Offers are being registered for the purpose of secondary resales, any securityholder using the Exchange
Offers to participate in a distribution of the Registered Notes (1) could not rely on the Staff's position enunciated in Exxon
Capital Holdings Corporation (available May 13, 1988) or similar letters and (2) must comply with registration and prospectus
delivery requirements of the Act in connection with any sale or transfer of the Registered Notes, unless the sale or transfer is made
pursuant to an exemption from those requirements. Each of the Company and the Guarantor acknowledge that such a secondary resale transaction
should be covered by an effective registration statement containing the selling securityholder information required by Item 507 of Regulation
S-K.

 In addition, the Company and the Guarantor will (i) make each
person participating in the Exchange Offers aware (through the Exchange Offer prospectus) that any broker-dealer who holds Restricted
Notes acquired for its own account as a result of market-making activities or other trading activities, and who receives Registered Notes
in exchange for such Restricted Notes pursuant to the Exchange Offers, may be a statutory underwriter and must deliver a prospectus meeting
the requirements of the Act in connection with any resale of such Restricted Notes and (ii) include in the transmittal letter to
be submitted to the Exchange Agent by an exchange offeree in order to participate in the Exchange Offers a provision to the following
effect:

 If the undersigned or any beneficial
owner is a broker-dealer, the undersigned and such beneficial owner: (1) represents that it is participating in the Exchange Offers
for its own account and is exchanging Restricted Notes that were acquired by it as a result of market-making or other trading activities,
(2) confirms that it has not entered into any arrangement or understanding with any person to distribute the Restricted Notes and
(3) acknowledges that it will deliver a prospectus meeting the requirements of the Act in connection with any resale of such Restricted
Notes; however, by so acknowledging and by delivering a prospectus, such broker-dealer will not be deemed to admit that it is an
underwriter within the meaning of the Act.

 See Shearman & Sterling (available July 2, 1993).

 [Signature Page Follows]

 Very
 truly yours,

 CONOCOPHILLIPS

 By:
 /s/ Philip M. Gresh III

 Name:
 Philip M. Gresh III

 Title:
 Vice President, Investor Relations and Treasurer

 CONOCOPHILLIPS
 COMPANY

 By:
 /s/ Philip M. Gresh III

 Name:
 Philip M. Gresh III

 Title:
 Vice President, Investor Relations and Treasurer