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October 10, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Division of Corporation Finance

Office of Energy & Transportation

Washington, D.C. 20549

Attention: Joseph Klinko, Mark Wojciechowski,

Sandra Wall and Brad Skinner

    Re:
    Texas Pacific Land Corporation

Form 10-K for the Fiscal Year ended December 31, 2024

Filed February 19, 2025

File No. 001-39804

Ladies and Gentlemen:

On behalf of Texas Pacific
Land Corporation (the “Company”), below is the response of the Company to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) set forth in the letter from the Division of Corporation
Finance and Office of Energy & Transportation, dated September 19, 2025, with respect to the above-referenced filing.

To assist with your review,
we have repeated the text of the Staff's comments in italic type immediately preceding our response.

Form 10-K for the Fiscal Year ended December
31, 2024

Properties, page 17

1. Please expand your filing to include a summary of your oil and gas reserves at fiscal year-end. Refer
to the disclosure requirements in Items 1202(a)(1) through 1202(a)(4) of Regulation S-K.

RESPONSE:

The Company acknowledges the
Staff’s comment and respectfully advises that the Company intends to include the requested information in “Item 2. Properties”
in its Form 10-K for the fiscal year ending December 31, 2025, which the Company expects to file with the Commission in February 2026.
Please see the section titled “Summary of Estimated Proved Developed Producing (“PDP”) Reserves” in the attached
Annex B for an example of the Company’s planned disclosure.

2. We note that you have not previously disclosed reserves estimates
in a filing with the Commission and that you are disclosing material additions to your reserves estimates. Accordingly, explain to us
how you considered providing a general discussion of the technologies used to establish the appropriate level of certainty for reserves
estimates from material properties included in the total reserves disclosed. See Item 1202(a)(6) of Regulation S-K.

RESPONSE:

To establish reasonable certainty
for its estimated proved reserves, the technologies and economic data used in the estimation included actual production data, downhole
completion information, geologic data, and historical well cost and operating expense data. The Company intends to include the requested
information in “Item 2. Properties” in its Form 10-K for the fiscal year ending December 31, 2025, which the Company expects
to file with the Commission in February 2026. Please see the section titled “Proved Reserves Evaluation and Review of Estimated
Proved Producing Reserves” in the attached Annex B for an example of the Company’s planned disclosure.

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

Office of Energy & Transportation

October 10, 2025

Page 2

3. Disclose and describe the internal controls you use in your reserves estimation effort. In addition,
disclose the qualifications of the technical person primarily responsible for overseeing the preparation of the reserves estimates and,
if you represent that a third party conducted a reserves audit, disclose the qualifications of the technical person primarily responsible
for overseeing such reserves audit. See Item 1202(a)(7) of Regulation S-K.

RESPONSE:

The Company acknowledges the
Staff’s comment and respectfully advises that the Company intends to include the requested information in “Item 2. Properties”
in its Form 10-K for the fiscal year ending December 31, 2025, which the Company expects to file with the Commission in February 2026.
Please see the section titled “Proved Reserves Evaluation and Review of Estimated Proved Producing Reserves” in the attached
Annex B for an example of the Company’s planned disclosure.

4. Expand your disclosure to include total gross and net productive wells, expressed separately for oil
and gas, associated with your interests. Refer to the disclosure requirements in Item 1208(a) of Regulation S-K.

RESPONSE:

The Company acknowledges the
Staff’s comment and respectfully advises that the Company intends to include the requested information in “Item 2. Properties”
in its Form 10-K for the fiscal year ending December 31, 2025, which the Company expects to file with the Commission in February 2026.
Please see the section titled “Productive Wells” in the attached Annex B for an example of the Company’s planned
disclosure.

5. Please expand your acreage disclosure to provide a break-out of gross and net developed and undeveloped
acreage. Refer to the disclosure requirements in Item 1208(b) of Regulation S-K.

RESPONSE:

The Company acknowledges the
Staff’s comment and respectfully advises that the Company only reports reserves for producing properties and does not maintain a
list of undeveloped properties. Because (i) the mineral owner of the Company’s legacy non-participating royalty interest (Chevron
USA, Inc.) often elects to self-develop or jointly develop minerals without leasing, and (ii) as a non-participating royalty owner, the
Company has little insight into leasing and planned development, the Company believes it would be misleading to categorize all of its
non-producing acreage as undeveloped acreage.

Management’s Discussion and Analysis
of Financial Condition and Results of Operations Year Ended December 31, 2024 Compared to Year Ended December 31, 2023 Land and Resource
Management, page 26

6. Please expand your disclosure to provide the last three fiscal years of production and average sales
prices. Refer to the disclosure requirements in Item 1204 of Regulation S-K.

RESPONSE:

The Company acknowledges the
Staff’s comment and respectfully advises that the Company intends to provide the requested information in “Item 1. Business
 – Business Segments – Land and Resource Management” in its discussion of “Operations of the Land and Resource
Management Segment” in its Form 10-K for the fiscal year ended December 31, 2025, which the Company expects to file with the Commission
in February 2026. The Company believes this placement is more appropriate in “Item 1. Business” as its discussion in “Results
of Operations” in “Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations”
focuses on current year results as opposed to results from the prior year. Please see the section titled “Operations” in attached
Annex A for an example of the Company’s planned disclosure.

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

Office of Energy & Transportation

October 10, 2025

Page 3

Non-GAAP Performance Measures, page 27

7. We note your presentation of a non-GAAP financial measure titled ‘Free Cash Flow’. Please
address the following:

 · You identify Free Cash Flow as performance measure, but the label suggests it may be a liquidity measure.
Tell us the specific facts and circumstances that led you to conclude this is a performance measure. If you continue to believe Free Cash
Flow is a performance measure, tell us how you determined it is appropriate to exclude cash-based adjustments in the calculation of a
performance measure. Refer to Questions 100.01 and 100.05 of the Non-GAAP Financial Measures C&DI’s.

 · Regardless of whether you conclude Free Cash Flow is a performance or liquidity measure, please revise
your non-GAAP reconciliation to reconcile the measure to the most directly comparable GAAP measure, rather than presenting a “compound”
reconciliation from Net Income to Adjusted EBITDA then to Free Cash Flow.

 · Please disclose the reasons why you believe Free Cash Flow provides useful information to investors
and any additional purposes for which management uses this measure. Refer to Items 10(e)(1)(i)(C) and (D) of Regulation S-K.

 · Finally, we note you define Free Cash Flow as Adjusted EBITDA less current income tax expense and capital
expenditures. Per your consolidated Statement of Cash Flows, Cash flows from investing activities, total capital expenditures (excluding
acquisitions of a business) appears to be $426.7 million ($395,577 + $1,476 + $29,696). Please revise your reconciliation accordingly,
or tell us why the amount presented in the reconciliation differs from this amount, and explain the differences.

This comment also applies to your
Forms 10-Q and earnings releases.

RESPONSE:

The Company acknowledges the
Staff’s comment and respectfully advises that the Company believes that free cash flow is an important performance metric for measuring
the Company’s performance for investors, and the Company does not consider this metric to be a liquidity measure. Due to the Company’s
unique history, a sizable amount of the Company’s value is recorded at a zero-book basis (i.e., approximately 800,000 surface
acres and approximately 455,000 gross royalty acres in West Texas), resulting in a low book value for the Company. Further, each of the
Company’s business segments has high margins with low capital expenditure requirements, and the Company maintains a conservative
capital structure with limited to no debt. As noted in Note 11, “Income Taxes” of the Company’s Consolidated Financial
Statements included in its Form 10-K for the fiscal year ended December 31, 2024, the Company’s effective income tax rate was 21.6%
due in large part to its low book value and high-margin business segments, thus the Company pays significant income taxes at or near the
corporate tax rate. The Company further believes free cash flow demonstrates the cash available for investing and returning capital to
its stockholders through dividends and share repurchases. We believe that investors appreciate that the nature of the Company’s
business is high margin, with a low capital expenditure burden and conservative capital structure, and that free cash flow best reflects
the overall performance of the Company.

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

Office of Energy & Transportation

October 10, 2025

Page 4

Secondarily, as noted in the
section titled “2024 Compensation Program” in the “2024 Annual (Short-Term) Incentive Program Summary” and the
 “2024 Long-Term Incentive Program” sub-sections on pages 47 and 48 of its Form 10-K for the fiscal year ended December 31,
2024, incentive compensation for the Company’s Named Executive Officers (the “NEOs”) is dependent upon not only
achievement of strategic objectives set by the Compensation Committee of the Board of Directors (the “Compensation Committee”),
but also upon two performance metrics: (i) adjusted EBITDA and (ii) free cash flow. The Company reports both of these performance metrics
as non-GAAP performance measures beginning on page 27 of the Form 10-K for the fiscal year ended December 31, 2024. The Compensation Committee
implemented these two measures as part of the Company’s incentive compensation program to increase alignment between the NEOs’
interests and the interests of the Company’s stockholders. Specifically, generating free cash flow enables greater returns to stockholders
in the form of dividends and share repurchases. As noted on page 47 of the Company’s Form 10-K for the fiscal year ended December
31, 2024, the weighting of free cash flow per fully diluted share on the Company’s 2024 annual short-term incentive program was
increased from 37.5% to 50% after considering feedback from the Company’s stockholders, further highlighting the importance of free
cash flow as a performance measure.

In further response to the
Staff’s comments identified in the second bullet point above, the Company intends to include a separate reconciliation of net income
to free cash flow in its reconciliation of “Non-GAAP Performance Measures” in its Form 10-K for the fiscal year ending December
31, 2025, which the Company intends to file with the Commission in February 2026. Please see the attached Annex C for an example
of the Company’s planned disclosure. Additionally, the Company intends to apply these same changes to its Form 10-Q and earnings
release for the third quarter of 2025, which the Company expects to file with the Commission in November 2025.

Regarding the third bullet
point above, the Company intends to disclose its rationale for why it believes free cash flow provides useful information to investors
and how management uses the metric to measure its own performance for compensation purposes in its Form 10-K for the fiscal year ending
December 31, 2025, which the Company expects to file with the Commission in February 2026. Please see the attached Annex C for
a draft of the Company’s planned disclosure. Additionally, the Company intends to apply these same changes to its Form 10-Q and
earnings release for the third quarter of 2025, which the Company intends to file with the Commission in November 2025.

Regarding the fourth bullet
point above, the Company’s definition of free cash flow relates specifically to ongoing capital expenditures required of its business
and does not include adjustments for acquisitions of royalty interests, real estate or businesses. The Company intends to adjust its line-item
descriptions in its reconciliation of net income to free cash flow to match the line-item descriptions on the statement of cash flows
in its Form 10-K for the fiscal year ending December 31, 2025, which the Company expects to file with the Commission in February 2026.
Please see the attached Annex C for an example of the Company’s planned disclosure. Additionally, the Company intends to
apply these same changes to its Form 10-Q and earnings release for the third quarter of 2025, which the Company intends to file with the
Commission in November 2025.

Supplemental Oil and Gas Reserve Information
(Unaudited)

Analysis of Changes in Oil and Natural Gas
PDP Reserves, page F-32

8. We note your disclosure on page 3 that the average realized price received per Boe during the year
2024 decreased 6.4% from the year 2023; however, the reconciliation of the changes in proved reserves during 2024 does not include a negative
revision due to prices. Please review and revise your disclosure to identify and quantify the net amount of change due to the decrease
in commodity prices, and any other contributing factors, including offsetting factors, so the change due to revisions of prior estimates
is fully explained. Refer to the disclosure requirements in FASB ASC 932-235-50-5(a).

RESPONSE:

The Company acknowledges the
Staff’s comment and respectfully advises that, as noted in the second paragraph on page F-32 of its Form 10-K for the fiscal year
ended December 31, 2024, reserve studies were not completed in prior periods. The comparative information presented is based upon the
reserve report as of December 31, 2024, and the Company rolled back actual volumes from 2024 to 2021. Based on the conservative well life
estimates used and the robust economics of Permian wells, the Company believes it is unlikely that Permian wells will need revision absent
a significant market change in price. Accordingly, there were no prior estimates to be revised for these time frames. The Company intends
to add a line item for revisions to this table in future years that will reflect revisions made during the year. For the Company’s
Form 10-K for the fiscal year ending December 31, 2025 and the Company’s subsequent Form 10-K filings, a line item for revisions
will be added to this table for the period from December 31, 2024 to December 31, 2025.

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

Office of Energy & Transportation

October 10, 2025

Page 5

In subsequent filings, the
Company intends to include all periods that are presented in the change in estimated reserves table in the summary table.

9. Please expand the disclosure of t