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CORRESP Filing

Viper Energy, Inc.
Date: July 17, 2025 · CIK: 0002074176 · Accession: 0001193125-25-160554

Offering / Registration Process

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File numbers found in text: 333-288431

Date
July 17, 2025
Author
Matt Zmigrosky
Form
CORRESP
Company
Viper Energy, Inc.

Letter

Re: New Cobra Pubco, Inc.

New Cobra Pubco, Inc. 500 West Texas Ave., Suite 100 Midland, TX 79701 July 17, 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. 20549-7010 Attention: Cheryl Brown

Registration Statement on Form S-4

File No. 333-288431

Request for Acceleration Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, New Cobra Pubco, Inc., a Delaware corporation (the “ Registrant ”), hereby requests acceleration of effectiveness of its registration statement on Form S-4 (File No. 333-288431), as amended, to 4:01 p.m. Eastern Time on July 18, 2025, or as soon as practicable thereafter. The Registrant hereby authorizes Steven Green of Wachtell, Lipton, Rosen & Katz to orally modify or withdraw this request for acceleration. If you have any questions concerning this request, or if you require any additional information, please feel free to contact Steven Green of Wachtell, Lipton, Rosen & Katz at (212) 403-1035 or by email at SRGreen@wlrk.com. Please notify him when this request for acceleration has been granted.

Very truly yours,
NEW COBRA PUBCO, INC.

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CORRESP
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 CORRESP

 New Cobra Pubco, Inc.
 500 West Texas Ave., Suite 100
 Midland, TX 79701 July 17, 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. 20549-7010
 Attention: Cheryl Brown

 Re:
 New Cobra Pubco, Inc.

  
 Registration Statement on Form S-4

  
 File No. 333-288431

  
 Request for Acceleration
 Ladies and Gentlemen: Pursuant to
Rule 461 under the Securities Act of 1933, as amended, New Cobra Pubco, Inc., a Delaware corporation (the “ Registrant ”), hereby requests acceleration of effectiveness of its registration statement on Form S-4 (File No. 333-288431), as amended, to 4:01 p.m. Eastern Time on July 18, 2025, or as soon as practicable thereafter.
 The Registrant hereby authorizes Steven Green of Wachtell, Lipton, Rosen & Katz to orally modify or withdraw this request for
acceleration. If you have any questions concerning this request, or if you require any additional information, please feel free to
contact Steven Green of Wachtell, Lipton, Rosen & Katz at (212) 403-1035 or by email at SRGreen@wlrk.com. Please notify him when this request for acceleration has been granted.

 Very truly yours,

 NEW COBRA PUBCO, INC.

 By:

 /s/ Matt Zmigrosky

 Name:

 Matt Zmigrosky

 Title:

 Executive Vice President, Secretary and General Counsel

 cc:
 Steven Green, Wachtell, Lipton, Rosen & Katz