DEVON ENERGY CORPORATION
333. W. SHERIDAN AVE
OKLAHOMA, CITY, OKLAHOMA 73102-5015
TELEPHONE (405) 235-3611
November 20, 2020
VIA EDGAR
Ms. Karina Dorin and Loan Lauren Nguyen
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Devon Energy Corporation |
Registration Statement on Form S-4 |
File No. 333-249859 |
Dear Ms. Dorin and Ms. Nguyen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Devon Energy Corporation respectfully requests that the effective date of the above-referenced Registration Statement on Form S-4 be accelerated by the staff of the U.S. Securities and Exchange Commission to November 24, 2020 at 9:00 a.m., Eastern Time, or as soon thereafter as practicable.
Please contact Eric Otness of Skadden, Arps, Slate, Meagher & Flom LLP at (713) 655-5135 with any questions you may have regarding this request. In addition, please notify Mr. Otness by telephone when this request for acceleration has been granted.
| /s/ Jeffrey L. Ritenour |
| Jeffrey L. Ritenour |
Executive Vice President and Chief Financial Officer Devon Energy Corporation |
| cc: | Eric Otness, Esq. |
Frank Bayouth, Esq.
Skadden, Arps, Slate, Meagher & Flom LLP
Sean T. Wheeler, Esq.
Debbie Yee, Esq.
Michael Rigdon, Esq.
Kirkland & Ellis LLP
