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Correspondence 0001193125-24-033979 from APA Corp (APA)

APA Corp
Date: Feb. 13, 2024 · CIK: 0001841666 · Accession: 0001193125-24-033979

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File numbers found in text: 333-276797

Date
February 13, 2024
Author
By
Form
CORRESP
Company
APA Corp

Letter

VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Attention: Michael Purcell APA Corporation Registration Statement on Form S-4, as amended File No. 333-276797 Request for Acceleration of Effective Date

Dear Mr. Purcell:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-4 (the “Registration Statement”), filed by APA Corporation (the “Company”) with the U.S. Securities and Exchange Commission on January 31, 2024, as amended on February 13, 2024, be accelerated to February 15, 2024 at 5:00 p.m. Eastern Time or as soon thereafter as may be practicable.

The Company hereby authorizes Zachary Podolsky of Wachtell, Lipton, Rosen & Katz, to orally modify or withdraw this request for acceleration.

If you have any questions regarding the foregoing, please contact Zachary Podolsky at 212-403-1057. Please notify him when this request for acceleration has been granted.

*****

Very truly yours,
By:

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 APA Corporation

2000 Post Oak Boulevard, Suite 100

 Houston, TX 77056

 February 13, 2024

 VIA EDGAR

 Division of Corporation Finance

 Securities and
Exchange Commission

 100 F Street, N.E.

 Washington,
D.C. 20549

 Attention: Michael Purcell

  

Re:

 APA Corporation

 Registration
Statement on Form S-4, as amended

 File No. 333-276797

Request for Acceleration of Effective Date

 Dear Mr. Purcell:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration
Statement on Form S-4 (the “Registration Statement”), filed by APA Corporation (the “Company”) with the U.S. Securities and Exchange Commission on January 31, 2024, as amended on February 13, 2024, be accelerated
to February 15, 2024 at 5:00 p.m. Eastern Time or as soon thereafter as may be practicable.

 The Company hereby authorizes
Zachary Podolsky of Wachtell, Lipton, Rosen & Katz, to orally modify or withdraw this request for acceleration.

 If you have any
questions regarding the foregoing, please contact Zachary Podolsky at 212-403-1057. Please notify him when this request for acceleration has been granted.

*****

Very truly yours,

By:

/s/ P. Anthony Lannie

Name:

P. Anthony Lannie

Title:

Executive Vice President and General Counsel