SecProbe.io

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 July 25, 2025

Jeffrey Magids
Vice President and Chief Financial Officer
Berry Corp (bry)
16000 Dallas Parkway, Suite 500
Dallas, Texas 75248

 Re: Berry Corp (bry)
 Form 10-K for Fiscal Year Ended December 31, 2024
 Filed March 13, 2025
 File No. 001-38606
Dear Jeffrey Magids:

 We have reviewed your filing and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Business and Properties
Production Data, page 10

1. Please expand the disclosure of your average daily production to
additionally provide
 the average sales prices, net production quantities by final product
sold, and average
 production costs per unit of production, for each of the last three
fiscal years to
 comply with Item 1204 of Regulation S-K.
Proved Undeveloped Reserves Changes, page 15

2. We note disclosure provided in Form 10-K for the fiscal years ending
December 31,
 2024, 2023, 2022, 2021 and 2020 indicates you converted approximately
9%, 2%,
 6%, 13% and 0%, respectively, of the opening balance of your proved
undeveloped
 reserves during each of those periods.

 We also note that you have removed material amounts of previously
disclosed proved
 undeveloped reserves during each of the last three fiscal years due to
changes in your
 July 25, 2025
Page 2

 five-year development plan and that based on your fiscal 2024 conversion
rate, it will
 take over eleven years to convert the proved undeveloped reserves
disclosed as of
 December 31, 2024.

 Please tell us how you have taken into consideration your low historical
conversion
 rates and the ongoing changes in your development plans in adopting a
development
 plan that results in the conversion of the 45.6 MMBoe of proved
undeveloped reserves
 as of December 31, 2024 within five years of initial disclosure of such
reserves. Refer
 to Rule 4-10(a)(31)(ii) of Regulation S-X and the Question 131.04 in the
Compliance
 and Disclosure Interpretations (C&DIs) regarding Oil and Gas Rules.
3. Please provide us with the development schedule relating to your proved
undeveloped
 reserves as of December 31, 2024, including details that show for each
future annual
 period, (1) the number of gross wells to be drilled, (2) the associated
net quantities of
 reserves, (3) the estimated capital expenditures necessary to convert
such reserves to
 developed reserves, and (4) any changes made or expected to be made in
the schedule
 that would deviate from the definition in Rule 4-10(a)(31)(ii) of
Regulation S-X.
Participation in Wells Being Drilled, page 20

4. Please expand the disclosure of your present activities to include the
number of gross
 and net operated and non-operated wells in the process of being drilled,
completed, or
 waiting on completion, and any other related activities of material
importance as of
 December 31, 2024 to comply with Item 1206 of Regulation S-K.
Drilling Activity, page 20

5. Please expand the disclosure of drilling activities that occurred during
each of the last
 three fiscal years to include wells drilled by operators other than you
to comply with
 Item 1205 of Regulation S-K.
Supplemental Oil & Natural Gas Data (Unaudited)
Standardized Measure of Discounted Future Net Cash Flows, page 162

6. We note the future production costs used in the calculation of the
standardized
 measure of discounted future net cash flows for the year ended December
31, 2024
 excludes the $263.3 million dollar expense line item shown in Exhibit
99.1 relating to
 payments made by the Company to the State of California to comply with
the
 California Air Resources Board s Cap-and-Trade Program. As a result,
the
 undiscounted pre-tax future net income in the filing is $263.3 million
or 7.7% higher
 than the comparable figure in Exhibit 99.1. Please review and revise if
necessary, here
 and elsewhere in your filing, to resolve the inconsistency or expand
your disclosure to
 explain your rationale for omitting the payments to the State of
California. Refer to
 the disclosure requirements in FASB ASC 932-235-50-36.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 July 25, 2025
Page 3

 Please contact John Hodgin at 202-551-3699 if you have questions
regarding the
engineering comments. Please contact Craig Arakawa, Branch Chief, at
202-551-3650 with
any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Energy &
Transportation
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