SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 15, 2025

John J. Christmann, IV
Director and Chief Executive Officer
APA Corp
2000 W. Sam Houston Pkwy S., Suite 200
Houston, Texas 77042

 Re: APA Corp
 Registration Statement on Form S-4
 Filed August 8, 2025
 File No. 333-289400
Dear John J. Christmann IV:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Irene Barberena-Meissner at 202-551-6548 with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Troy Harder, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 CORRESP

 August 15, 2025
 VIA EDGAR United States Securities and Exchange
Commission Division of Corporation Finance Office of Energy
and Transportation 100 F. Street, N.E. Washington, D.C.
20549 Attention: Irene Barberena-Meissner

 Re:
 APA Corporation
 Registration Statement on Form S-4
 Filed August 8, 2025 File No. 333-289400 Ladies and Gentlemen:
 Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, APA Corporation hereby requests acceleration of the effective
date of its Registration Statement on Form S-4 (File No. 333-289400) (the “Registration Statement”). We respectfully request that the Registration
Statement become effective as of 10:00 a.m., Washington, D.C. time, on August 19, 2025, or as soon as practicable thereafter. Please
contact Troy Harder, of Bracewell LLP, counsel to the Company, at (713) 221-1456, if you have any other questions or concerns regarding this request. In addition, please notify Mr. Harder by telephone
when this request for acceleration has been granted.

 Very truly yours,

 APA Corporation

 By:

 /s/ Aneil Kochar

 Name:

 Aneil Kochar

 Title:

 Vice President and Treasurer

August 28, 2024
Rebecca A. Hoyt
Senior Vice President and Chief Accounting Officer
APA Corp
One Post Oak Central
2000 Post Oak Boulevard, Suite 100
Houston, Texas 77056-4400
Re:APA Corp
Annual Report on Form 10-K for the fiscal year ended December 31, 2023
Filed February 22, 2024
File No. 001-40144
Dear Rebecca A. Hoyt:
            We have completed our review of your filing. 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.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation

CORRESP
1
filename1.htm

CORRESP

 FOIA confidential treatment requested by APA Corporation

Pursuant to 17 C.F.R. § 200.83 (Rule 83)

 August 15, 2024

 VIA
EDGAR

 Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Energy and Transportation

 100
F Street, N.E.

 Washington, D.C. 20549

 Attn: Brad Skinner
and Sandra Wall

Re:
 APA Corporation

Annual Report on Form 10-K for the fiscal year ended December 31, 2023

Filed February 22, 2024

File No. 001-40144

Ladies and Gentlemen:

 Set forth below are the
responses of APA Corporation, a Delaware corporation (“we,” “our,” or the “Company”), to the comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by letter dated July 23, 2024, with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023, File No. 001-40144 (the “Form 10-K”), filed with the Commission on February 22, 2024.

For the Staff’s convenience, each response is prefaced by the exact text of the Staff’s corresponding comment in bold, italicized
text, followed by our response to each comment in regular type. All references to page numbers and captions correspond to the Form 10-K unless otherwise indicated.

Pursuant to Rule 83 of the Commission’s Rules on Information and Requests, 17 C.F.R. § 200.83 (“Rule 83”), the
Company is requesting confidential treatment for the Company’s response to Comment 2 below, which has been redacted from the version of this response letter filed via EDGAR and marked by bracketed asterisks (“[***]”) (the
“Redacted Information”). In accordance with Rule 83, the Company requests the Redacted Information be maintained in confidence, not be made part of any public record, and not be disclosed to any person, including in response to any request
under the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”). A complete unredacted copy of this response letter is being provided to the Commission under separate cover along with the request for confidential treatment under
Rule 83.

APA Corporation   2000 W Sam Houston Pkwy S, Suite 200, Houston, TX 77042 | apacorp.com

 FOIA confidential treatment requested by APA Corporation

Pursuant to 17 C.F.R. § 200.83 (Rule 83)

Annual Report on Form 10-K for the fiscal year ended December 31, 2023

Operating Areas

 Other Exploration, page 6

1.
 You disclose that successful appraisal of two key oil discoveries “confirmed combined recoverable
resources of an estimated 700 million barrels of oil for the two fields”. Please note that disclosure of quantities other than reserves in an annual report on Form 10-K is generally prohibited. See
the instruction to Item 1202 of Regulation S-K and revise your disclosure accordingly.

Response:

 We acknowledge the
Staff’s comment. The Company will not disclose estimates of oil or gas resources other than reserves, or any estimated values of such resources, in any future documents publicly filed with the Commission. Set forth below is the disclosure from
page 6 of the Form 10-K revised to comply with the Staff’s request as an example of the type of disclosure we intend to include in future public filings with the Commission.

“During 2023, the Company and TotalEnergies announced the launch of development studies for a large oil project in Block 58, offshore
Suriname. The results from the drilling and testing of two wells at Sapakara South and three wells at Krabdagu confirmed our geologic, geophysical, and reservoir models for the fields. These fields, located in water depths between 100 and
1,000 meters, are expected to be produced through a system of subsea wells connected to a floating production, storage and offloading unit located 150 kilometers off the Suriname coast, with an oil production capacity of 200,000 b/d. Detailed
engineering studies are underway, and a final investment decision is expected by year-end 2024, with a first production target in 2028. No additional drilling is anticipated on Block 58 through the end of
2024.”

 Business Overview

 Upstream
Exploration and Production

 Drilling Statistics, page 7

2.
 We note that 7.7 net wells (10%) of the 73.8 net development wells drilled in Egypt during 2023 were dry;
however, during the prior five years (2018 to 2022) only 3 net development wells (1%) of the total 226.7 net development wells drilled in Egypt were dry. Please provide as supplemental information a reasonably detailed explanation for the higher dry
hole rate during 2023, including any effect on your future development plans in Egypt. Additionally, tell us the following:

a.
 Whether any proved undeveloped reserves were included for the 7.7 net dry wells at year-end 2022, and if so, the quantity of those reserves and where the downward revision is reflected in the 2023 reserve roll-forward;

b.
 Whether and how actual drilling results differed from assumptions underlying the decision to drill these
wells;

 Page 2 of 3

 FOIA confidential treatment requested by APA Corporation

Pursuant to 17 C.F.R. § 200.83 (Rule 83)

c.
 Whether the results on these wells led you to reevaluate reserve estimates for any other wells; and,

d.
 Where any downward revisions attributable to any related wells are reflected in the 2023 reserve
roll-forward.

 Response:

[***]

 In addition to the foregoing, the Company
acknowledges that:

•

 The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

 Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking
any action with respect to the filing; and

•

 The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

 Please direct any questions or comments regarding the
foregoing to the undersigned at (713) 296-6800 or to Courtney Cochran Butler, outside counsel to the Company, at (713) 220-4396.

Very truly yours,

APA CORPORATION

By:

/s/ Rebecca A. Hoyt

Rebecca A. Hoyt

Senior Vice President, Chief Accounting Officer, and Controller

cc:
 Courtney Cochran Butler (By Email)

Hunton Andrews Kurth LLP

 600
Travis, Suite 4200

 Houston, TX 77002

CourtneyButler@HuntonAK.com

 Page 3 of 3

CORRESP
1
filename1.htm

CORRESP

 July 26, 2024

 FILED
VIA EDGAR

 Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549

 Attn: Brad Skinner, Senior Assistant Chief Accountant

Re:
 APA Corporation

Annual Report on Form 10-K for the fiscal year ended December 31, 2023

Filed February 22, 2024

File No. 001-40144

Ladies and Gentlemen:

 APA Corporation
(“APA”) submits this letter in connection with the comments from the staff of the Securities and Exchange Commission received by letter dated July 23, 2024 (the “Comment Letter”) relating to the above referenced filing of
APA.

 APA is working expeditiously to respond to the Comment Letter. APA respectfully requests an extension of time to respond to the
inquiries contained in the Comment Letter. APA currently anticipates submitting a response to the Comment Letter on or before August 15, 2024.

Please do not hesitate to contact me at (713) 296-6800 with any concerns you may have regarding this
timetable described above. Thank you for your consideration.

Respectfully,

/s/ Rebecca A. Hoyt

Rebecca A. Hoyt

Senior Vice President and Chief Accounting Officer

APA Corporation

2000 W Sam Houston Pkwy S, Suite 200, Houston, TX 77042 | apacorp.com

July 23, 2024
Rebecca A. Hoyt
Senior Vice President and Chief Accounting Officer
APA Corp
One Post Oak Central
2000 Post Oak Boulevard, Suite 100
Houston, Texas 77056-4400
Re:APA Corp
Annual Report on Form 10-K for the fiscal year ended December 31, 2023
Filed February 22, 2024
File No. 001-40144
Dear Rebecca A. Hoyt:
            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.
Annual Report on Form 10-K for the fiscal year ended December 31, 2023
Operating Areas
Other Exploration, page 6
1.
You disclose that successful appraisal of two key oil discoveries "confirmed combined
recoverable resources of an estimated 700 million barrels of oil for the two fields".  Please
note that disclosure of quantities other than reserves in an annual report on Form 10-K is
generally prohibited.  See the instruction to Item 1202 of Regulation S-K and revise your
disclosure accordingly.
Business Overview
Upstream Exploration and Production
Drilling Statistics, page 7
We note that 7.7 nets wells (10%) of the 73.8 net development wells drilled in Egypt
during 2023 were dry; however, during the prior five years (2018 to 2022) only 3 net 2.

July 23, 2024
Page 2
development wells (1%) of the total 226.7 net development wells drilled in Egypt were
dry. Please provide as supplemental information a reasonably detailed explanation for the
higher dry hole rate during 2023, including any effect on your future development plans
in Egypt.  Additionally, tell us the following:
•Whether any proved undeveloped reserves were included for the 7.7 net dry wells at
year-end 2022, and if so, the quantity of those reserves and where the downward
revision is reflected in the 2023 reserve roll-forward;
•Whether and how actual drilling results differed from assumptions underlying the
decision to drill these wells;
•Whether the results on these wells led you to reevaluate reserve estimates for any
other wells; and,
•Where any downward revisions attributable to any related wells are reflected in the
2023 reserve roll-forward.

            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.
            Please contact Sandra Wall at 202-551-4727, Petroleum Engineer, or Brad Skinner,
Office Chief, at 202-551-3489 if you have questions regarding the engineering comments or
related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation

United States securities and exchange commission logo
February 12, 2024
John J. Christmann IV
Chief Executive Officer
APA Corporation
2000 Post Oak Boulevard, Suite 100
Houston, TX 77056
Re:APA Corporation
Registration Statement on Form S-4
Filed February 1, 2024
File No. 333-276797
Dear John J. Christmann IV:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Michael Purcell at 202-551-5351 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Zachary Podolsky

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