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  Suite 1900, 205– 5th Avenue SW

Calgary, Alberta

T2P 2V7

December 31, 2024

By Electronic Submission

Division of Corporation Finance

Office of Energy & Transportation

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

  Attn:
  Steve Lo

  Craig Arakawa

Re: Form 20-F for the Fiscal Year Ended December 31, 2023

File No. 001-41810

Dear Mr. Lo and Mr. Arakawa,

This letter is submitted on behalf of Greenfire Resources Ltd. (“Greenfire”
or the “Company”), in response to the comment that you provided on behalf of the Division of Corporation Finance of the Securities
and Exchange Commission in your letter dated December 17, 2024.

For your convenience, we have set forth the original comment from your
letter below.

Comment

We note you have identified oil sales as the
most directly comparable measure to your non-GAAP measure, operating netback and have provided a reconciliation along those lines. Given
that the calculation of the measure adjusts GAAP revenues by non-revenue related items (i.e. expenses), it would appear that a GAAP measure
of profitability, rather than revenues, should be identified as the most directly comparable GAAP measure. Please tell us why you consider
revenues to be the most directly comparable IFRS measure or revise your reconciliation accordingly. Refer to Item 10(e)(1)(i)(A) of Regulation
S-K.

Response

Greenfire uses operating netback to assess its
financial and operating performance, specifically its ability to generate a cash margin (“operating margin”) on a unit of
production basis. Operating netback measures the Company’s operational efficiency, meaning how efficiently it turns Oil sales
into an operating margin. Greenfire believes that Oil sales (or “revenue”) is the most directly comparable GAAP measure, rather
than a profitability measure such as Net income (loss) because Oil sales directly correlates to the cash inflows generated from the sale
of oil, the key driver to the Company’s operating netback. Using a profitability metric such as net income (loss) introduces a number
of large non-operational charges, such as depreciation, financing costs, gains or losses and taxes, which are unrelated to a cash operating
margin per unit of production. As a result, Greenfire believes Net income (loss) is less directly comparable, making the reconciliation
process more complex and less transparent.

  Suite 1900, 205– 5th Avenue SW

Calgary, Alberta

T2P 2V7

Reconciling operating netback to revenue is consistent
with the method of calculation Greenfire is required to use and disclose under applicable Canadian securities laws. In addition to being
a reporting “foreign private issuer” under the U.S. Securities Exchange Act of 1934, Greenfire is also a “reporting
issuer” in the Canadian provinces of Alberta and Ontario. As a Canadian reporting issuer, Greenfire is also obligated to comply
with Canadian continuous disclosure obligations, including National Instrument 51-101: Standards of Disclosure for Oil and Gas Activities
(“NI 51-101”) and the Canadian Oil and Gas Evaluation Handbook (“COGE Handbook”). Section 4.2 of the
consolidated third edition of the COGE Handbook concerns the calculation of netback, which is as follows:

The netback calculation takes the price
received for a unit of production at a specific time and deducts from it all production costs, royalties, and production taxes to find
the cash netback to the producer from each unit of production, usually a bbl of oil or a Mcf of sales gas. The netback calculation is
not used for identifying asset value. It is best used as an operations indicator to assess operating priorities and evaluate smaller capital
expenditures normally associated with field maintenance and improvement at a specific time. Annual netback can be assessed historically
to understand the operation efficiency of a project. Forecasts of netback can provide an understanding of future operational efficiency.

Importantly, NI 51-101 mandates that if a
reporting issuer discloses netback, it must calculate it “by subtracting royalties and operating costs from revenues and state
the method of calculation.”1  By aligning its
reconciliation with revenue, Greenfire is disclosing netback consistent with the requirements of NI 51-101, providing comparability
and consistency with its Canadian reporting issuer peers (including other US reporting foreign private issuers).

The computation of operating netback can begin
with either Oil sales (“revenue-down”) or Net income (loss) (“net-income-up”). Objectively, Oil sales is a closer
GAAP measure to operating netback, as it requires only five adjustments to reconcile, compared to the fifteen adjustments2
needed to compute operating netback from Net income (loss).

As a result of the aforementioned NI 51-101 disclosure
requirement, Greenfire’s stakeholders, including investors and analysts, are accustomed to interpreting operating netback in relation
to revenue. This practice ensures that the information the Company provides is both relevant and easily understood within the context
of industry norms. Aligning the reconciliation with revenues supports the transparency and usability of Greenfire’s financial disclosures,
facilitating better decision-making for its stakeholders.

Conclusion

Greenfire considers Oil Sales to be the
most directly comparable GAAP measure to Operating netback because:

 1. Operating netback directly represents the operating margin generated by those oil sales making revenue
the more immediate and relevant starting point;

 2. It is in compliance with the calculation requirements of NI 51-101 and the COGE Handbook;

 3. It reflects an industry-specific measure of operational efficiency, distinct from a measure of profitability
or cash flows;

 4. It is an objectively closer GAAP measure requiring fewer adjustments resulting in a more transparent reconciliation;
and

 5. It meets stakeholder expectations and fosters increased comparability with industry peers.

Based on this and the additional considerations
above, Greenfire believes its approach aligns with applicable regulatory requirements and industry practices, adheres to relevant guidance
under Item 10(e)(1)(i)(A) of Regulation S-K, enhances transparency, and delivers a clear and accurate representation of the metric’s
purpose and calculation.

 1 See Section 5.8.2 of Companion Policy 51-101 Standards of Disclosure
for Oil and Gas Activities.

 2 When using Q4 2023 figures.

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  Suite 1900, 205– 5th Avenue SW

Calgary, Alberta

T2P 2V7

Given the rationale detailed above and to further
enhance the clarity and transparency of Greenfire’s financial disclosures, it will revise its non-GAAP disclosure in the Q4 2024
Management Discussion and Analysis to the following:

Operating Netback

Operating netback and operating netback excluding
realized gain (loss) on risk management contracts are common financial measures used in the oil and gas industry, utilized by Greenfire’s
to assess its operating performance and ability to generate an operating margin on a unit of production basis. Our Operating Netback calculation
is aligned with the definition found in the Canadian Oil and Gas Evaluation Handbook. Operating netback consists of oil sales, less diluent
expense, royalties, operating expense, transportation and marketing expense, adjusted for realized commodity risk management gains or
losses, as appropriate. Operating netback is adjusted for the realized gain (loss) on risk management contracts to provide a more complete
picture of Greenfire’s financial performance as financial derivatives are used to provide price certainty on a portion of its production.
See the “Results of Operations – Operating Netback” section in this MD&A for a reconciliation of oil sales to operating
netback.

Should you have any further questions or require
additional information, please do not hesitate to contact us.

Thank you for your attention to this matter.

Sincerely,

  /s/ Tony Kraljic

  Tony Kraljic

  Chief Financial Officer

  Greenfire Resources Ltd.

  403-668-5298

  Tkraljic@greenfireres.com

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