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CORRESP
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CORRESP

 August 21, 2013

 Mr. H. Roger Schwall

 Assistant Director

Division of Corporation Finance

 U.S. Securities
and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549-3628

Re:
SandRidge Energy, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2012

 Filed March 1, 2013

 Form 10-Q for the Fiscal Quarter ended
March 31, 2013

 Filed May 8, 2013

 Definitive Proxy Statement on Schedule 14A

 Filed May 29, 2013

 File No. 001-33784

 Dear Mr. Schwall,

 SandRidge Energy, Inc. (the “Company” or
“SandRidge”) hereby submits this letter in response to the written comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated July 30, 2013
(the “Comment Letter”), with respect to the Form 10-K for the fiscal year ended December 31, 2012 filed by SandRidge with the Commission on March 1, 2013 (the “2012 Form 10-K”); the Form 10-Q for the
fiscal quarter ended March 31, 2013 filed by SandRidge with the Commission on May 8, 2013; the Definitive Proxy Statement on Schedule 14A filed by SandRidge with the Commission on May 29, 2013; and certain information on the
Company’s website.

 Set forth below is the heading and text of each comment set forth in the Comment Letter, followed by
our response thereto. In addition, on August 8, 2013, the Company filed with the Commission its Quarterly Report on Form 10-Q for the fiscal quarter ended June 30, 2013 (the “Second Quarter Form 10-Q”). The proposed
disclosure set forth below in response to certain of the comments was included in the Second Quarter Form 10-Q. The Company undertakes to include similar disclosure in its future annual reports on Form 10-K and quarterly reports on Form 10-Q and, to
the extent applicable, in other future filings. Capitalized terms used but not otherwise defined herein have the respective meanings ascribed to them in the 2012 Form 10-K, or, in the case of disclosures included in the Second Quarter Form 10-Q, the
respective meanings ascribed to them therein.

 Form 10-K for the Fiscal Year ended December 31, 2012

 Mr. H. Roger Schwall

 U.S. Securities and Exchange Commission

  Page
 2

 Business, page 1

 Business Segments and Primary Operations, page 4

 West Texas Overthrust, page 6

 1. Please revise your disclosure to discuss and quantify (i) the annual amount of natural gas that you would be required to
deliver to meet the carbon dioxide delivery requirement, (ii) the annual carbon dioxide delivery requirement, and (iii) the liquidated damages per 1,000 standard cubic feet of carbon dioxide not delivered. Alternatively, provide the
information necessary to understand the potential impact to earnings and liquidity if it is reasonably possible that you will be unable to meet your long-term contractual obligations under the treating agreement. Please also disclose the
relationship between the natural gas input and carbon dioxide output, and the methodology that liquidation damages are calculated to comply with Item 1207 of Regulation S-K.

 Response

 We acknowledge the Staff’s comment. Set forth below
is proposed disclosure which we believe responds to the Staff’s comment. We undertake to include this disclosure (updated appropriately) in future annual reports on Form 10-K and quarterly reports on Form 10-Q. We also note for the Staff that
this disclosure was included in Note 11 on page 33 of the Second Quarter Form 10-Q.

 In conjunction
with the Century Plant construction agreement, the Company entered into a 30-year treating agreement with Occidental for the removal of CO2 from the Company’s delivered production volumes. Under the agreement, the Company must deliver a total of
approximately 3,200 Bcf of CO2 during the agreement period;
it is expected that after 2013 approximately 3,000 Bcf of CO2
will remain to be delivered. The company pays Occidental $0.25 per Mcf to the extent minimum annual CO2 volume requirements are not met, and, at the end of 2042, the Company is required to pay Occidental $0.70 per Mcf for total undelivered CO2 volumes, net of any CO2 delivered in excess of any given year’s applicable minimum volumes. Based on current projected natural gas production
levels the Company expects to accrue between approximately $29.5 million and $36.0 million at December 31, 2013 for amounts related to the Company’s anticipated shortfall in meeting its 2013 annual delivery obligations. Due to the
sensitivity of drilling activity to market prices for natural gas, the Company is unable to estimate additional amounts it may be required to pay under the agreement in subsequent periods; however, if natural gas prices remain low, drilling activity
will likely also remain low, which would result in additional shortfall payments in future periods.

 With respect to the last sentence of the Staff’s comment, the Company notes that there is no constant relationship between the quantity of natural gas delivered at the Century Plant for treatment and
the amount of carbon dioxide delivered to Occidental with respect to such natural gas. Rather, the natural gas stream’s carbon dioxide content varies from well to well. We note for the Staff’s information, that since 2007, the high
CO2 content natural gas produced by the Company in the
Piñon Field has contained, on average 65.7% carbon dioxide, ranging from a low of 63.1% to a high of 68.7%.

 Mr. H. Roger Schwall

 U.S. Securities and Exchange Commission

  Page
 3

 Although the Company is providing additional disclosure regarding the Occidental
treating agreement in response to the Staff’s comment, as indicated above, the Company notes that Item 1207 of Regulation S-K directs a registrant to disclose fixed and determinable quantities of oil or gas that it is
committed to deliver under existing contracts or agreements. Under the Company’s treating agreement with Occidental, the Company’s delivery obligation is for the delivery of specified volumes of carbon dioxide and not for the delivery of
specified volumes of natural gas. Therefore, Item 1207 by its terms does not apply to the annual payments made by the Company to Occidental pertaining to underdelivery of carbon dioxide.

 Reserve Quantities, PV-10 and Standardized Measure, page 10

 2. You state “the
Company estimates that approximately 80% of its current proved undeveloped reserves will be developed by the end of 2014 and all of its current proved undeveloped reserves will be developed by the end of 2016.” For purposes of determining the
five year period, Item 1203(d) of Regulation S-K identifies the initial disclosure and date thereof as the starting reference date. Please tell us if any of your proved undeveloped volumes disclosed as of December 31, 2012 will take more
than five years since initial disclosure to develop.

 Response

We note the Staff’s comment and confirm that none of the Company’s proved undeveloped oil and natural gas reserves disclosed
as of December 31, 2012 are expected to take more than five years since initial disclosure to develop.

 3. The footnote to the
reserves disclosure on pages 10 and F-65 states that prior to 2012, NGLs did not comprise a significant portion of total proved reserves and were included with oil reserves. Please tell us the net quantities of NGLs for 2011 and 2010 and explain how
you have determined disclosure of these quantities was not warranted per the requirements set forth in FASB ASC 932-235-50-4.

Response

 The
Company’s proved NGL reserves were 6% and 9% of total proved reserves at December 31, 2011 and 2010, respectively. FASB ASC 932-235-50-4 provides that “reserve quantity information shall be disclosed separately for natural gas
liquids” if significant. The definition of significant oil and gas producing activities found in FASB ASC 932-235-20 states that an entity is regarded as having significant oil and gas producing activities if (a) revenues from,
(b) results of operations for or (c) identifiable assets of oil and gas producing activities are 10% or more of the entity’s total respective revenue, results of operations or identifiable assets. By applying the same 10% criteria to
determine the significance of NGL reserves to the Company’s total reserves, the Company determined NGL reserves at December 31, 2011 and 2010 were not significant on the basis of their percentage of total reserves and were therefore not
required to be separately disclosed for these periods.

 Mr. H. Roger Schwall

 U.S. Securities and Exchange Commission

  Page
 4

 Proved Undeveloped Reserves, page 12

 4. Item 1203(b) of Regulation S-K requests that registrants “[d]isclose material changes in proved undeveloped reserves that occurred during the year, including proved undeveloped reserves
converted into proved developed reserves.” It appears you have disclosed only the PUD volumes that you converted to proved developed status. Please expand your disclosure to provide a reconciliation of the material changes in the net quantities
of your proved undeveloped reserves due to revisions, extensions/discoveries, acquisition/divestiture and improved recovery.

Response

 We
acknowledge the Staff’s comment and note that the balance of the Company’s proved undeveloped reserves did not change materially from December 31, 2011 to December 31, 2012 (they increased from approximately 240 MMBoe at
December 31, 2011 to approximately 246 MMBoe at December 31, 2012, a change of only 2.5%). However, the Company included disclosure of proved undeveloped reserves converted to proved developed status during the year, in response to
Item 1203(b) of Regulation S-K, which specifically calls for such disclosure. Given the overall absence of a material change in the balance of proved undeveloped reserves year over year, we submit that Item 1203(b) does not require
more detailed disclosure, nor does it call for a reconciliation of changes in the net quantities of proved undeveloped reserves due to the specific factors noted in the Staff’s comment. In future annual reports on Form 10-K, we will
undertake to include disclosure of changes to proved undeveloped reserves due to revisions, extensions/discoveries, acquisition/divestiture and improved recovery, to the extent such factors cause material changes in the Company’s proved
undeveloped reserves.

 Production and Price History, page 14

 5. Your disclosure of the production and average sales price on page 14 and elsewhere in this Form 10-K excludes separate disclosure of information relating to natural gas liquids. As Items 1204(a)
and 1204(b)(1) of Regulation S-K require separate disclosure by final product sold or produced, please advise or revise your disclosure to provide separate disclosure relating to natural gas liquids.

Response

 The
Company’s NGL production was 6%, 8% and 8% of total production for the years ended December 31, 2012, 2011 and 2010, respectively. The Company applied the 10% “significance” criteria from FASB ASC 932-235-20 described above (see
response to Comment 3) to determine the significance of NGL production to the Company’s total production, and concluded that NGL production for the years ended December 31, 2012, 2011 and 2010 was not significant based on the percentages
it constituted of total production and was therefore not separately disclosed.

 Developed and Undeveloped Acreage, page 15

 Mr. H. Roger Schwall

 U.S. Securities and Exchange Commission

  Page
 5

 6. We note from the disclosure on page 15 that a significant percentage of the Company’s net
undeveloped acreage will expire in 2013 and 2014. Please tell us the net amounts by product of your December 31, 2012 proved undeveloped oil and gas reserves assigned to locations on acreage scheduled to expire in 2013 and in 2014. Also tell us
if all such proved undeveloped locations are included in a development plan adopted by management as of December 31, 2012 indicating that these locations are scheduled to be drilled prior to lease expiration.

Response

Approximately 97% of the Company’s net undeveloped acreage scheduled to expire in 2013 and 2014 are leases in the states of Texas,
Oklahoma and Kansas. Approximately 99% of the expiring Texas leases are in the West Texas Overthrust. The Company had no proved undeveloped oil and natural gas reserves assigned to these locations at December 31, 2012 due to depressed natural
gas index prices. The proved undeveloped oil and gas reserves assigned to Oklahoma and Kansas acreage scheduled to expire in 2013 and 2014 constituted approximately 1.3% of the Company’s total net proved oil and gas reserves at
December 31, 2012. All locations associated with these reserves are scheduled to be drilled prior to lease expiration.

 Risk Factors

 “Unless the Company replaces its oil and natural gas reserves…,” page 35

7. Please expand this risk factor to discuss the impact of the February 2013 sale of the Permian Basin properties.

Response

 We
acknowledge the Staff’s comment. Set forth below is disclosure included on page 75 of the Second Quarter Form 10-Q under the heading “Item 1B. Risk Factors.” (revisions to disclosures in the 2012 Form 10-K underlined), which we
believe responds to the Staff’s comment. We undertake to include this disclosure, as appropriate, in future annual reports on Form 10-K.

Unless the Company replaces its oil and natural gas reserves, its reserves and production will decline, which would adversely affect the
Company’s business, financial condition and results of operations.

 In February 2013, the Company closed
the sale of the Permian Properties, which accounted for 21% of the Company’s total production in the fourth quarter of 2012 and 35% of the Company’s reserves at December 31, 2012. The Company’s future oil and natural gas
reserves and production, and therefore its cash flow and income, are highly dependent on its success in efficiently developing and exploiting its current reserves and economically finding or acquiring additional recoverable reserves. The Company may
not be able to develop, find or acquire additional reserves to replace its current and future production at acceptable costs, which could adversely affect its business, financial condition and results of operations.

 Mr. H. Roger Schwall

 U.S. Securities and Exchange Commission

  Page
 6

 “The Company’s development and exploration operations require substantial
capital…,” page 37

 8. Please provide context for this risk factor by quantifying the amount of your capital expenditures
in the recent past financed from asset sales and sales of equity and debt, as compared to those capital expenditures financed from cash generated from operations. Similarly, quantify the amount of capital expenditure that the Company
“expects” to finance from asset sales and other financing arrangements and sales of equity and debt, as compared to those capital expenditures expected to be financed from cash generated from operations.

Response

 We note
to the Staff that, just as the Company has multiple sources of cash, it also has various funding needs in addition to its capital expenditures, such as general and administrative costs, lease operating expenses, interest expense and taxes. Further,
the Company considers its various cash inflows to be fungible and does not allocate specific cash inflows or potential specific sources of cash to specific expenses. Therefore, the Company is unable to quantify the amount of recent past, or expected
future, capital expenditures that have been financed through asset sales or capital markets transactions, as compared to cash generated from operations or other sources of cash. We also note that the discussion of cash flows in the MD&A section
of the 2012 Form 10-K provides detail on the various sources of the Company’s cash.

 Management’s Discussion and Analysis, page
61

 Results by Segment, page 62

 9. We see that you have disclosed on page 64 average prices related to your oil and natural gas production reflecting