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Correspondence Letter

 January 7, 2013

 Mr. Perry Hindin

 Special Counsel, Office of Mergers and Acquisitions

Division of Corporate Finance

 U.S. Securities
and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549-3628

Re:
SandRidge Energy, Inc.

Preliminary Consent Revocation Statement on Schedule 14A

 Filed December 27, 2012

 Soliciting material filed pursuant to
Exchange Act Rule 14a-12

 Filed December 21, 2012

File No. 001–33784

Dear Mr. Hindin,

On behalf of our client, SandRidge Energy, Inc. (the “Company” or “SandRidge”), we hereby submit this
letter in response to the written comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated January 4, 2013 (the “Comment Letter”), with
respect to the Preliminary Consent Revocation Statement on Schedule 14A filed by SandRidge with the Commission on December 27, 2012 (the “Preliminary Consent Revocation Statement”) and the soliciting material filed pursuant to
Exchange Act Rule 14a-12 by SandRidge with the Commission on December 21, 2012.

 Set forth below is the heading and text
of each comment set forth in the Comment Letter, followed by our response thereto. Capitalized terms used but not otherwise defined herein have the respective meanings ascribed to them in the Preliminary Consent Revocation Statement. In addition,
SandRidge is simultaneously filing Amendment No. 1 to the Preliminary Consent Revocation Statement with the Commission to, among other matters, amend the Preliminary Consent Revocation Statement in response to the Comment Letter.

1. We note the disclosure in the soliciting material filed on December 21, 2012 regarding the Company’s receipt of
written consents from a stockholder of record, dated December 19, 2012. Given that TPG-Axon had not yet filed a consent statement disclosing its three proposals and identifying its nominees and had not yet furnished the Company’s
stockholders with a consent card relating to its three proposals, please advise us why the

 Division of Corporate Finance

 U.S. Securities and Exchange Commission

 January 7, 2013

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Company believes it appropriate to conclude that the stockholder communication received by the Company constituted written consents to TPG-Axon’s consent solicitation. Include in your
response letter (i) a detailed legal analysis supporting the Company’s conclusion, (ii) the identity of the stockholder of record who submitted the written consent and (iii) the number of shares of Company stock beneficially held
by such stockholder. If the stockholder of record is an entity, please identify the natural person or persons who have voting and investment power over the shares. Also tell us in your response letter whether such natural person is an affiliate of
the Company or a “related person,” as that term is defined in the Instructions to Item 404(a) of Regulation S-K. Please also provide us a copy of the written consents.

 Response

 On December 19, 2012, the Company received two
written consents executed by Cede & Co., the nominee of The Depository Trust Company and the record holder of 381,972,517 shares of Company Common Stock on December 13, 2012, the record date for the TPG-Axon Consent Solicitation. One
consent, with respect to 100 shares beneficially owned by Tom L. Ward, consented to the adoption of the proposals previously announced by TPG-Axon Partners, LP to (i) amend the Company’s Bylaws to eliminate the division of the
Company’s Board into classes and to permit the removal of directors by stockholders with or without cause (the “Bylaw Amendment Proposal”), and (ii) remove members of the Board as proposed by TPG-Axon Partners, LP. The
other consent, with respect to 100 shares beneficially owned by Tom L. Ward IRA, consented to the adoption of the Bylaw Amendment Proposal. Mr. Ward is the Chairman and Chief Executive Officer of the Company and is an affiliate of the Company
and a “related person” within the meaning of Item 404(a) of Regulation S-K. There was no consent filed on December 19, 2012 with respect to the proposal by the TPG-Axon Group to replace removed directors with nominees of
TPG-Axon.

 These consents were provided pursuant to Section 228 of the General Corporation Law of the State of Delaware
(the “DGCL”) which states, in relevant part, that no stockholder written consent shall be effective to take the corporate action referred to therein unless, within 60 days of the earliest dated consent delivered in the manner
required by the statute, written consents signed by a sufficient number of stockholders to take the action referred to therein are delivered to the corporation in the manner required by the statute. The statute does not require such earliest dated
consent to be delivered by the stockholder who initiated the consent solicitation or that such delivery occur after consent cards have been furnished to stockholders. Furthermore, other than requiring that a written consent set forth the action so
taken, be signed by a holder of outstanding stock and bear the date of signature of each stockholder signing such written consent, the statute does not prescribe the form a consent must take. The Company believes that the public announcements by
TPG-Axon Partners, LP and its affiliates prior to December 19, 2012 accurately described in substance both Proposal No. 1 (“Proposal 1”) and Proposal No. 2 (“Proposal 2”), as set forth in the
Preliminary Consent Statement filed by the TPG-Axon Group with the Commission on December 26, 2012 (the “TPG-Axon Consent Statement”), and that the consents delivered to the Company clearly identify their subjects as Proposals
1 and 2. Accordingly, the Company, after consultation with Covington & Burling LLP and Potter

 Division of Corporate Finance

 U.S. Securities and Exchange Commission

 January 7, 2013

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Anderson & Corroon LLP, its outside counsel, has concluded that the written consents filed on December 19, 2012 are the earliest dated consents within the meaning of
Section 228 of the DGCL for purposes of determining the 60-day period within which stockholders must deliver a sufficient number of unrevoked consents to adopt Proposal 1 and Proposal 2.

In response to the Staff’s request, we will promptly provide the Commission with a copy of the above-referenced written consents in
a supplemental letter submitted to the Staff, together with a request for confidential treatment pursuant to Rule 83 of the Commission’s Rules Concerning Information and Requests (17 C.F.R. § 200.83).

2. Revise the disclosure to advise stockholders that, notwithstanding the date of any TPG-Axon consent statement furnished to such
stockholders or the date that any consent furnished by TPG-Axon to stockholders is first delivered to the Company, the Company has determined that it will not count any consents delivered to the Company after the date that is 60 days after
December 19, 2012. Disclose that specific date.

 Response

In response to the Staff’s comment, the disclosure on page 11 of the Preliminary Consent Revocation Statement under the subheading
“When should I return my Consent Revocation Card?” has been revised to advise stockholders that the Company will not count any consents that are delivered to the Company after February 17, 2013, which is the date that is 60 days after
December 19, 2012, notwithstanding the date of any consent statement furnished by the TPG-Axon Group to the Company’s stockholders or the date that any consent card furnished by the TPG-Axon Group to stockholders is first delivered to the
Company.

 Reasons to Reject the TPG-Axon Consent Proposals, page 4

3. Please provide support for the statement appearing here and elsewhere in the disclosure that TPG-Axon is “an opportunistic
investor with short-term interests.”

 Response

In support of this statement, we note to the Staff that TPG-Axon has publicly described a sale of the Company as its preferred strategic
course. For example, in TPG-Axon’s November 30, 2012 letter to the Company’s Board, TPG-Axon states that “an outright sale of the company is the most realistic path to restoring the shareholder value that has been destroyed”
and “a sale of the company is best” because, among other reasons, “[u]ltimately, the value of the Mississippian assets is extraordinary, but so is the investment and time required to develop those assets.”

In support of this statement, we further note to the Staff the following facts, each of which is also disclosed in the third bullet point
on the top of page 7 of the Preliminary Consent Revocation Statement:

 Division of Corporate Finance

 U.S. Securities and Exchange Commission

 January 7, 2013

Page 4

•

 As disclosed in the TPG-Axon Consent Statement, TPG-Axon has sold approximately 5.3 million shares of the Company’s Common Stock since its
initial investment in the Company in November 2011.

•

 As disclosed in the TPG-Axon Consent Statement, TPG-Axon has sold shares of the Company’s Common Stock five times over the last year and three
times since July 2, 2012.

•

 Since 2011, TPG-Axon has made investments in three other companies involved in the exploration and production sector of the oil and gas business and
has on average only held such investments for approximately two fiscal quarters.

 4. In the last
sentence on the bottom of page 4 the Company indicates that stockholders should reject the TPG-Axon Consent because “TPG-Axon is not experienced in controlling or running an operating business.” Provide support for such statement. In
addition, since TPG-Axon Group Nominees, and not TPG-Axon itself, would serve on the board of directors, this statement does not appear relevant to this section’s heading. Please revise the disclosure to indicate that the TPG-Axon Group
Nominees, and not TPG-Axon, will serve on the board of directors if elected. Also explain in the disclosure why TPG-Axon’s experience in controlling or running an operating company is relevant to a stockholder’s voting decision regarding
the removal of the Company’s directors and their replacement with TPG-Axon Group Nominees.

 Response

In response to the Staff’s comment, the last sentence on the bottom of page 4 of the Preliminary Consent Revocation Statement has
been revised to state that Mr. Singh, one of the TPG-Axon Group Nominees and the Chief Executive Officer of TPG-Axon Capital, is not experienced in running an operating business. This statement is based on the disclosures set forth in the
TPG-Axon Consent Statement and our review of publicly available information, in which we were not able to find any instance where Mr. Singh had experience in running an operating business. We believe this disclosure is relevant because
Mr. Singh is one of the TPG-Axon Group Nominees, and as Chief Executive Officer of TPG-Axon Capital has played a leading role in initiating and pursuing the TPG-Axon Consent Solicitation, which we believe, based on public statements by TPG-Axon
(including its November 30, 2012 letter to the Board) is intended to facilitate a sale or dramatic restructuring of the Company.

 In response to the Staff’s comment, this disclosure has also been revised to indicate that that the TPG-Axon Group Nominees will constitute all the members of the Board if the TPG-Axon Consent
Proposals are successful.

 5. Revise the disclosure to describe the strategic plan referenced at the top of page 5 and
explain why the Company believes it will deliver long-term value to stockholders.

 Division of Corporate Finance

 U.S. Securities and Exchange Commission

 January 7, 2013

Page 5

 Response

 In response to the Staff’s comment, the disclosure in the first bullet point at the top of page 5 of the Preliminary Consent Revocation Statement has been revised.

6. Refer to the fifth bullet point on the top of page 5. Revise the disclosure to explain why the vesting of restricted shares
would “jeopardize the Company’s ability to retain its management and operating personnel.” It is unclear if this statement is suggesting key management and operating personnel would voluntarily terminate their employment with the
Company following a change of control or only that the Company would have to create other incentives to retain such individuals.

Response

 In
response to the Staff’s comment, the disclosure in the fifth bullet point at the top of page 5 of the Preliminary Consent Revocation Statement has been revised.

 The TPG-Axon Consent Solicitation is an attempt…, page 5

 7.
Refer to the last sentence of the second bullet point in this section. Please revise the disclosure to support the statement that the TPG-Axon Group “may have different interests from, and [sic] in conflict with, the best interests of all of
the Company’s stockholders” given that (i) the group includes the TPG-Axon Group Nominees, who, according to TPG-Axon’s consent statement, will all be considered independent directors of the Company under the Company’s
Corporate Governance Guidelines, under applicable NASDAQ rules and under Item 407(a) of Regulation S-K, (ii) six of the seven nominees do not currently have or have ever had any business or financial ties to TPG-Axon or any of its
affiliated funds and (iii) all of the nominees are subject to the same fiduciary duties under Delaware General Corporation Law as the current Company’s directors.

 Response

 In response to the Staff’s comment, the statement
that the TPG-Axon Group “may have different interests from, and in conflict with, the best interests of all of the Company’s stockholders” has been deleted.

 8. Refer to our preceding comment and the fourth bullet point in this section. Please revise the last sentence to indicate that the TPG-Axon Group Nominees, and not TPG-Axon, will serve on the board
of directors, if elected, and explain why TPG-Axon’s experience in controlling or running an operating company is relevant to a stockholder’s voting decision regarding the removal of the Company’s directors and their replacement with
TPG-Axon Group Nominees.

 Division of Corporate Finance

 U.S. Securities and Exchange Commission

 January 7, 2013

Page 6

 Response

 In response to the Staff’s comment, the disclosure in the fourth bullet point in this section of the Preliminary Consent Revocation Statement has been revised to, among other things, state that
Mr. Singh, one of the TPG-Axon Group Nominees and the Chief Executive Officer of TPG-Axon Capital, is not experienced in running an operating business. Please also see our response to the Staff’s comment in paragraph 4 above.

The Board believes that the TPG-Axon Group Nominees are not in a position…, page 6

9. Refer to the third bullet point in this section. Please revise the disclosure to support the statement that the TPG-Axon Group
“has no duty to act in the best interests of the Company’s stockholders” given that (i) the group includes the TPG-Axon Group Nominees, who, according to TPG-Axon’s consent statement, will all be considered independent
directors of the Company under the Company’s Corporate Governance Guidelines, under applicable NASDAQ rules and under Item 407(a) of Regulation S-K, (ii) six of the seven nominees do not currently have or have ever had any business or
financial ties to TPG-Axon or any of its affiliated funds and (iii) all of the nominees are subject to the same fiduciary duties under Delaware General Corporation Law as the current Company directors. If the Company intended to refer to
TPG-Axon as opposed to the TPG-Axon Group, please revise the disclosure to explain why TPG-Axon’s lack of “duty to act in the best interests of the Company’s stockholders” is relevant to this section’s subheading or relevant
to a stockholder’s voting decision with respect to the TPG-Axon Group Nominees, who do have such duties.

 Response

 In response to the Staff’s comment, the disclosure in the third bullet point in this section of the Preliminary
Consent Revocation