SecProbe.io

November 21, 2025
Tyler Glover
President, Chief Executive Officer and Director
Texas Pacific Land Corporation
1700 Pacific Avenue, Suite 2900
Dallas, TX 75201
Re:Texas Pacific Land Corporation
Form 10-K for the Fiscal Year ended December 31, 2024
File No. 001-39804
Dear Tyler Glover:
            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
cc:Chris Steddum

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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

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October 1, 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:

Texas Pacific Land Corporation
(the “Company”) acknowledges receipt of the comment letter, dated September 19, 2025 (the “Letter”),
from the staff of the Division of Corporation Finance and Office of Energy & Transportation (the “Staff”) of the
United States Securities and Exchange Commission (the “Commission”) with respect to the Company’s Annual Report
on Form 10-K for the Fiscal Year ended December 31, 2024 filed with the Commission on February 19, 2025.

Further to the Company’s
conversations with the Staff following the Company’s receipt of the Letter, the Company respectfully informs the Staff that it will
provide its responses to each of the comments set forth in the Letter via EDGAR as soon as possible, and in any event no later than October
10, 2025.

If you have any questions
or require any additional information, please do not hesitate to contact the undersigned at (214) 969-5530 or the Company’s counsel,
Rachel O’Donnell of Haynes and Boone, LLP, at (214) 651-5204 or Rachel.ODonnell@haynesboone.com. Thank you very much.

    Very truly yours,

    /s/ Tyler Glover

    Tyler Glover

    President, Chief Executive Officer and Director

    cc:

    Chris Steddum, Chief Financial Officer

    Micheal W. Dobbs, Senior Vice President, Secretary and General Counsel

    Deloitte & Touche LLP

    Haynes and Boone, LLP

September 19, 2025
Tyler Glover
President, Chief Executive Officer and Director
Texas Pacific Land Corporation
1700 Pacific Avenue
Suite 2900
Dallas, TX 75201
Re:Texas Pacific Land Corporation
Form 10-K for the Fiscal Year ended December 31, 2024
Filed February 19, 2025
File No. 001-39804
Dear Tyler Glover:
            We have reviewed your filing and have the following comments.
            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.
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.
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.
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 3.

September 19, 2025
Page 2
person primarily responsible for overseeing such reserves audit.  See Item 1202(a)(7)
of Regulation S-K.
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.
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.
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.
Non-GAAP Performance Measures, page 27
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.7.

September 19, 2025
Page 3

This comment also applies to your Forms 10-Q and earnings releases.
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).
9.Please expand the disclosure of the net developed reserves appearing below the table
of changes in estimated reserves to include the volumes as of the beginning of the
earliest period presented, i.e. as of December 31, 2021. Refer to the disclosure
requirements in FASB ASC 932-235-50-4.
            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 Joseph Klinko at (202) 551-3824 or Mark Wojciechowski at (202) 551-
3759 if you have questions regarding comments on the financial statements and related
matters. Please contact Sandra Wall, Petroleum Engineer, at (2 02) 551-4727 or Brad Skinner,
Office Chief, at (202) 551-3489 if you have any  questions regarding the engineering
comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Chris Steddum

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    Sidley
                                         Austin LLP

        1000
        Louisiana Street

        Suite
        5900

        Houston,
        TX 77002

        +1
        713 495 4500

        +1
        713 495 7799 Fax

        AMERICA
        ● ASIA PACIFIC ● EUROPE

December
29, 2020

VIA
EDGAR

John
Burr

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549-6010

    Re:
    Texas
                                         Pacific Land Corporation

        Form
        10 Registration Statement (File No. 001-39804)

        CIK
        No. 0001811074

Dear
Mr. Burr:

On behalf of Texas Pacific Land Corporation,
a Delaware corporation, we hereby request acceleration of the effective date of the above-referenced Registration Statement on
Form 10 so that it may become effective at 10:00 a.m., Eastern Time, on December 31, 2020, or as soon as possible thereafter. Once
the Registration Statement has been declared effective, please orally confirm that event with the undersigned at (713)-495-4522.

[Signature
appears on next page]

Sidley Austin
LLP is a limited liability partnership practicing in affiliation with other Sidley Austin partnerships.

U.S.
Securities and Exchange Commission

December
29, 2020

Page
2

    Very
    truly yours,

    /s/
    George J. Vlahakos

    George
    J. Vlahakos

 cc: Via
Email

Micheal
W. Dobbs, Texas Pacific Land Corporation

United States securities and exchange commission logo
July 14, 2020
Tyler Glover
Chief Executive Officer
Texas Pacific Land Corporation
1700 Pacific Avenue, Suite 2900
Dallas, Texas 75201
Re:Texas Pacific Land Corporation
Amended Draft Registration Statement on Form 10
Submitted July 2, 2020
CIK 0001811074
Dear Mr. Glover:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amended Draft Registration Statement on Form 10
Material U.S. Federal Income Tax Consequences, page 55
1.We note your revised disclosure that the corporate reorganization and distribution should
qualify as an F reorganization.  Accordingly, please provide disclosure explaining the
facts or circumstances resulting in this uncertainty, the degree of uncertainty, and add
appropriate risk factor disclosure.  For guidance, refer to Section III.C.4 of Staff Legal
Bulletin No. 19.
Exhibits
2.Please file the Stockholders' Agreement.  See Item 601(b)(10)(ii)(A) of Regulation S-K.

 FirstName LastNameTyler Glover
 Comapany NameTexas Pacific Land Corporation
 July 14, 2020 Page 2
 FirstName LastName
Tyler Glover
Texas Pacific Land Corporation
July 14, 2020
Page 2
            You may contact Paul Cline at 202-551-3856 or Shannon Menjivar at 202-551-3856  if
you have questions regarding comments on the financial statements and related matters.  Please
contact Michael Killoy at 202-551-7576 or Maryse Mills-Apenteng at 202-551-3457 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

United States securities and exchange commission logo
June 16, 2020
Tyler Glover
Chief Executive Officer
Texas Pacific Land Corporation
1700 Pacific Avenue, Suite 2900
Dallas, Texas 75201
Re:Texas Pacific Land Corporatino
Draft Registration Statement on Form 10
Submitted May 20, 2020
CIK 0001811074
Dear Mr. Glover:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form 10
Exhibit 99.1- Information Statement
Summary Selected Unaudited Pro Forma Condensed Consolidated Financial Information, page
10
1.Please tell us what consideration you gave to presenting pro forma financial statements
reflecting the changes to the historical financial statements of the Trust that are described
in a narrative format in this section.

 FirstName LastNameTyler Glover
 Comapany NameTexas Pacific Land Corporation
 June 16, 2020 Page 2
 FirstName LastNameTyler Glover
Texas Pacific Land Corporation
June 16, 2020
Page 2
The Corporate Reorganization and Distribution
The Number of Shares of TPL Corporation Common Stock You Will Receive, page 19
2.We note that TPL Trust will not distribute any fractional shares of TPL Corporation.
Please tell us whether any sub-certificate holders will receive less than the full value of
their current holdings.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 28
3.Please revise this section to discuss in greater detail the reasons for the changes in the
various results of operations.  For example, describe the reason for the 63.4% decrease in
pipeline easement income for the interim period and increase of 14.5% for the full year
period.  See Item 303(a)(3) of Regulation S-K and Section III.B.4 of SEC Release No. 33-
8350 (December 29, 2003).
Summary Compensation Table, page 47
4.Please disclose two of your most highly compensated executive officers other than the
principal executive and principal financial officers.  See Item 402(a)(3)(iv) of Regulation
S-K.
Material U.S. Federal Income Tax Consequences, page 53
5.We note the disclosure that the corporate reoganization will qualify as a tax-free
reorganization and that you will receive a tax opinion from counsel to that effect.  Please
file such tax opinion.  See Sec. III.A.2 of Staff Legal Bulletin No. 19 (October 14, 2011).
Index to the Financial Statements, page F-1
6.Please revise the index to the financial statements to provide an explanation as to why the
financial statements included in this Form 10 are not those of the registrant.
Exhibits
7.We note your disclosure that WPX Energy Permian, LLC accounted for 23% of total
revenues and Anadarko E&P Onshore, LLC, accounted for 14% of total revenues.
Accordingly, please disclose the material terms of the contracts and include the contracts
as exhibits.  See Item 601(b)(10)(ii)(B) of Regulation S-K.

 FirstName LastNameTyler Glover
 Comapany NameTexas Pacific Land Corporation
 June 16, 2020 Page 3
 FirstName LastName
Tyler Glover
Texas Pacific Land Corporation
June 16, 2020
Page 3
            You may contact Paul Cline at 202-551-3851 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Michael Killoy at 202-551-7576 or Maryse Mills-Apenteng at 202-551-3457 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction