UNITED STATES
                                 SECURITIES AND EXCHANGE COMMISSION
                                             WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                               April 5, 2019

  Via E-Mail

  Matthew P. Schwartz
  Gibson, Dunn & Crutcher LLP
  200 Park Avenue
  New York, New York 10166

          Re:     Texas Pacific Land Trust
                  PRRN14A filed on April 5, 2019
                  Filed by SoftVest, L.P. et al.
                  File No. 1-00737

  Dear Mr. Schwartz:

         The staff in the Office of Mergers and Acquisitions in the Division of
Corporation
  Finance has conducted a limited review of the revised filing listed above and
have the following
  additional comments:

  Revised Preliminary Proxy Statement filed on April 5, 2019

  Background to the Solicitation, page 2

      1. Refer to comment 7 in our letter dated April 2, 2019 and your
response. Your revised
         disclosure does not address your prior engagement with the Trust
regarding the three
         proposed restructuring plans you submitted in 2016. Please revise to
summarize those
         proposals and the potential impact on shareholders of the Trust.

      2. See our last comment above. Your revised disclosure in response to
prior comment 7 in
         our April 2, 2019 comment letter does not address your contacts with
the Trust in
         November 2018 and January 2019 concerning potential transactions with
third parties.
         For example, the Trust's proxy statement discloses that on November
28, 2018, you
         discussed the acquisition of the Trust by an oil and gas company and
on January 22,
         2019, you discussed a potential transaction between the Trust and a
different oil and gas
         company. Please revise to describe these contacts and whether you will
continue to
         advocate for these or other similar transactions if Mr. Oliver is
elected as a trustee.

      3. See comment 3 in our prior comment letter dated April 2, 2019 and your
response. With
         respect to your proposal to convert the Trust into a Delaware
corporation, expand the
         discussion of the potential impact on shareholders to explain the
effect on a third party's
 Michael P. Schwartz, Esq.
Gibson, Dunn & Crutcher LLP
April 5, 2019
Page 2

       (including your) ability to effect a change in control of the Trust if a
board of directors
       were to be annually elected.

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

       Please direct any questions to me at (202) 551-3263.


                                                              Sincerely,


                                                              /s/ Christina
Chalk


                                                              Christina Chalk
                                                              Senior Special
Counsel
                                                              Office of Mergers
and Acquisitions