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SEC Company Response from Kosmos Energy Ltd. (KOS) (CIK 0001509991) (KOS) — Jan 25, 2013

Kosmos Energy Ltd. (KOS) (CIK 0001509991)
Date: Jan. 25, 2013 · CIK: 0001509991 · Accession: 0001104659-13-004684

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File numbers found in text: 001-35167

Referenced dates: January 24, 2013

Date
January 25, 2013
Author
/s/ W. Greg Dunlevy
Form
CORRESP
Company
Kosmos Energy Ltd. (KOS) (CIK 0001509991)

Letter

January 25, 2013 Mr. Ethan Horowitz Accounting Branch Chief Securities and Exchange Commission 100 F Street N.E. Washington, DC 20549-4628

Re: Kosmos Energy Ltd. (the “Company”) Form 10-K for the Fiscal Year ended December 31, 2011 Filed March 1, 2012 File No. 001-35167

Dear Mr. Horowitz:

This letter is in response to the letter from the staff (the “Staff”) of the U.S. Securities and Exchange Commission to Kosmos Energy Ltd. (the “Company”) dated January 24, 2013 and the related teleconference call between the Company and the Staff on January 24, 2013. Please find attached for your review select pages of both the Company’s Form 10-K for the fiscal year ended December 31, 2011 (“Form 10-K”) and the Form 10-Q for the quarter ended September 30, 2012 (“Form 10-Q”). The pages relating to the Form 10-K have been marked to reflect the proposed changes to be included in a restatement of the Company’s audited financial statements for the fiscal year ended December 31, 2011, and will be included in a pending Form 10-K/A. The pages relating to the Form 10-Q have been marked to reflect the proposed changes to be included in a restatement of the Company’s unaudited financial statements for the fiscal quarter ended September 30, 2012, and will be included in a pending Form 10-Q/A.

To the extent that you have any questions regarding the response contained in this letter, please do not hesitate to contact me at (214) 445-9600.

Sincerely,
/s/ W. Greg Dunlevy

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CORRESP
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filename1.htm

January 25, 2013

Re:                             Kosmos Energy Ltd. (the “Company”)
 Form 10-K for the Fiscal Year ended December 31, 2011
 Filed March 1, 2012
 File No. 001-35167

Mr. Ethan Horowitz
 Accounting Branch Chief
 Securities and Exchange Commission
 100 F Street N.E.
 Washington, DC 20549-4628

Dear Mr. Horowitz:

This letter is in response to the letter from the staff (the “Staff”) of the U.S. Securities and Exchange Commission to Kosmos Energy Ltd. (the “Company”) dated January 24, 2013 and the related teleconference call between the Company and the Staff on January 24, 2013.  Please find attached for your review select pages of both the Company’s Form 10-K for the fiscal year ended December 31, 2011 (“Form 10-K”) and the Form 10-Q for the quarter ended September 30, 2012 (“Form 10-Q”).  The pages relating to the Form 10-K have been marked to reflect the proposed changes to be included in a restatement of the Company’s audited financial statements for the fiscal year ended December 31, 2011, and will be included in a pending Form 10-K/A. The pages relating to the Form 10-Q have been marked to reflect the proposed changes to be included in a restatement of the Company’s unaudited financial statements for the fiscal quarter ended September 30, 2012, and will be included in a pending Form 10-Q/A.

To the extent that you have any questions regarding the response contained in this letter, please do not hesitate to contact me at (214) 445-9600.

Sincerely,

/s/   W. Greg Dunlevy

W.   Greg Dunlevy

Executive   Vice President and Chief Financial Officer

cc:                                Brian F. Maxted

Richard D. Truesdell, Jr., Esq.

Kosmos Energy Ltd.

c/o Kosmos Energy, LLC 8176 Park Lane, Suite 500 Dallas, Texas 75231 Phone 214-445-9600 Fax 214 363 9024