United States securities and exchange commission logo March 9, 2022 James P. Henderson Executive Vice President Finance and Chief Financial Officer Whiting Petroleum Corporation 1700 Lincoln Street, Suite 4700 Denver, Colorado 80203-4547 Re: Whiting Petroleum Corporation Form 10-K for the Fiscal Year Ended December 31, 2020 Filed February 25, 2021 File No. 001-31899 Dear Mr. Henderson: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Energy & Transportation