April 29, 2019

David Edwards
Chief Financial Officer
Roan Resources, Inc.
14701 Hertz Quail Springs Pkwy
Oklahoma City, OK 73134

       Re: Roan Resources, Inc.
           Amendment No. 2 to Registration Statement on Form S-1
           Filed April 18, 2019
           File No. 333-227953

Dear Mr. Edwards:

      We have reviewed your amended 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our February 21,
2019 letter.

Form S-1/A filed April 18, 2019

Executive Compensation
Elements of Compensation
Annual Bonuses, page 108

1.     We note your new disclosure on page 108 describing annual bonuses
awarded "in light of
       our operating performance during the 2018 Fiscal Year." Please revise to
discuss
       generally the aspects of your fiscal 2018 operating performance that
were considered in
       awarding these bonuses. Refer to Item 402(b)(2)(v) and Instruction 2 to
Item 402(b) of
       Regulation S-K.
 David Edwards
FirstName LastNameDavid Edwards
Roan Resources, Inc.
Comapany NameRoan Resources, Inc.
April 29, 2019
Page 29,
April 2 2019 Page 2
FirstName LastName
       You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 with
questions
about engineering comments. If you have questions regarding comments on the
financial
statements and related matters, you may contact Jenifer Gallagher, Staff
Accountant, at (202)
551-3706 or John Cannarella, Staff Accountant, at (202) 551-3337. Please
contact Parhaum J.
Hamidi, Attorney-Adviser at (202) 551-3421 or Lauren P. Nguyen, Legal Branch
Chief, at (202)
551-3642 with any other questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Natural
Resources