October 22, 2019
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Natural Resources
100 F Street, NE
Washington, D.C. 20549-3561
| Attn: | Joseph Klinko |
| Karl Hiller |
| Re: | Gran Tierra Energy Inc. |
| Form 10-K for the Fiscal Year ended December 31, 2018 | |
| Filed February 27, 2019 | |
| File No.: 001-34018 |
Ladies and Gentlemen:
This letter sets forth the responses of Gran Tierra Energy Inc. (the “Company,” or “we”) to the comments received telephonically from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission on October 15, 2019 in response to the Company’s letter dated October 3, 2019 (the “Second Response Letter”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2018 (File No. 001-34018) filed with the Commission on February 27, 2019 and amended on April 16, 2019 (the “2018 Form 10-K”).
For the Staff’s convenience, we have included a summary of the Staff’s comment as received telephonically and provided our response below such comment.
Financial Statements
Supplementary Data (Unaudited), Page 77
| 1. | With respect to the Company’s response to Comment #3 contained in the Second Response Letter, the Staff requests that the Company revise its presentation of “Costs Incurred” in Schedule C to conform with the applicable disclosure illustration at FASB ASC 932-235-55-4. |
Response: In response to the Staff’s comment, in future filings, beginning with our Annual Report on Form 10-K for the year ended December 31, 2019, the Company will revise its disclosure to conform to the applicable disclosure illustration at FASB ASC 932-235-55-4, including removal of summations of select data.
October 22, 2019 Page 2 of 2 |
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If you have any questions with respect to the foregoing or if any additional supplemental information is required by the Staff, please contact Kristine Robidoux at (403) 698-7927 or Hillary H. Holmes of Gibson, Dunn & Crutcher LLP at (346) 718-6602.
| Very truly yours, | ||
| /s/ Ryan Ellson | ||
Ryan Ellson Chief Financial Officer |
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| Cc: | Gary S. Guidry, Gran Tierra Energy Inc. | |
| Kristine Robidoux, Gran Tierra Energy Inc. | ||
| Hillary H. Holmes, Gibson, Dunn & Crutcher LLP | ||
| Shane Doig, KPMG LLP | ||
| Cam Boulton, McDaniel & Associates Consultants Ltd. |