Mail Stop 4628
                                                           March 1, 2019

Robert M. Roosa
Chief Executive Officer and Director
Brigham Minerals, Inc.
5914 W. Courtyard Drive, Suite 100
Austin, TX 78730

       Re:    Brigham Minerals, Inc.
              Amendment No. 3 to
              Draft Registration Statement on Form S-1
              Submitted February 14, 2019
              CIK No. 0001745797

Dear Mr. Roosa:

      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.

Business, page 60

Proved, Probable and Possible Reserves, page 97

PUDs, page 101

1.     Your discussion of the changes in proved undeveloped reserves that
occurred in 2018
       indicates that the line item entry representing revisions in the
previous estimates of
 Robert M. Roosa
Brigham Minerals, Inc.
March 1, 2019
Page 2

       reserves is the result of an aggregation of two separate and unrelated
factors, e.g.
       development timing and EUR adjustments.

       Expand your disclosure to reconcile the overall change in the line item
by separately
       identifying and quantifying the net amount attributable to each factor
so that the
       change in net reserves between periods is fully explained. In
particular, disclosure
       relating to revisions in previous estimates should identify such
underlying factors as
       changes caused by commodity prices, well performance, improved recovery,
       uneconomic proved undeveloped locations or changes resulting from the
removal of
       proved undeveloped locations due to changes in a previously adopted
development
       plan. Refer to Item 1203(b) of Regulation S-K.

Financial Statements, page F-1

2.     Please address the financial statement updating requirements in Rule
3-12(b) of
       Regulation S-X for the registrant and predecessor.

Closing Comments

        You may contact John Cannarella, Staff Accountant, at (202) 551-3337 or
Karl
Hiller, Accounting Branch Chief, at (202) 551-3686 if you have questions
regarding
comments on the financial statements and related matters. For questions
regarding comments
on engineering matters, you may contact John Hodgin, Petroleum Engineer, at
(202) 551-
3699. Please contact Parhaum J. Hamidi, Attorney-Adviser, at (202) 551-3421 or,
in his
absence, Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any
other
questions.

                                                             Sincerely,

                                                             /s/ Lauren T.
Nguyen for

                                                             John Reynolds
                                                             Assistant Director
                                                             Office of Natural
Resources