SecProbe.io

Mail Stop 4628
July 29, 2016

Via Email
Thomas P. Chambers
Chief Financial Officer
Kosmos Energy Ltd.
Clarendon House
2 Church Street
Hamilton, Bermuda HM 11

Re: Kosmos Energy Ltd.
 Form 10 -K for Fiscal Year Ended
December 31, 2015
Filed February 22, 2016
 Response dated June 30, 2016
File No. 1-35167

Dear Mr. Chambers :

We have reviewed  your June 30, 2016  response to our comment letter and have the
following comments.  In some of our comments , we may ask you to provide us with information
so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.
Unless we no te otherwise, our references to prior comments are to comments in our June 23,
2016  letter .

Form 10 -K for Fiscal Year Ended December 31, 2015

Notes to Consolidated Financial Statements

Note 6 – Suspended Well Costs, page 112
1. Your response to prior  comment 2 states that you were not in a position to make a
determination concerning the commerciality of the Akasa Discovery based on the results
of your appraisal program as of March 31, 2015.  To further our understanding, describe
for us in suff icient detail the technical and/or economic issues that remain unresolved

Thomas P. Chambers
Kosmos Energy Ltd
July 29, 2016
Page 2

 which prohibit you from arriving at a determination of commerciality and how additional
technical studies and further evaluation will resolve such issues.
2. Your response to prior co mment 2 states that subsequent to your correspondence and
meeting with the Petroleum Commission on July 11, 2015, the government of Ghana has
been working through various other matters related to the Jubilee Field, which they have
deemed to be a more time sensitive priority for them.  Tell us the nature and timing of
your inquiries of or other communications that you have had with the government of
Ghana since July 11, 2015 regarding your request for additional time to perform technical
studies and e valuation of the Akasa Discovery.  Compare for us your experience
regarding the delays in responding to your requests or obtaining approvals from the
government regarding the Akasa Discovery to your experience with other comparable
projects in Ghana .
3. Your response to prior comment 2 states that you believe you are making sufficient
progress on assessing the reserves and the economic and operating viability of the Akasa
Discovery project.  We also note your capitalized exploratory well costs on comple ted
wells table on page 113.  Provide a similar rollforward for the Akasa Discovery’s
capitalized exploratory well costs as of and during the years ended December 31, 2015,
2014 and 2013.  Include in your response a thorough description of the additions to
capitalized exploratory well costs for each year.  Also, tell us the amount and nature of
any costs incurred subsequent to July 11, 2015 related to the Akasa Discovery, such as
costs incurred to assess the reserves and their potential development.

You may contact Diane Fritz, Staff Accountant, at (202) 551 -3331 or Kimberly L.
Calder, Assistant Chief Accountant, at (202) 551 -3701 with any questions.

Sincerely,

 /s/ Ethan Horowitz

        Ethan Horowitz
        Branch Chief
Office of Natural Resources