United States securities and exchange commission logo March 24, 2022 Richard H. Little Chief Executive Officer Battalion Oil Corporation 3505 West Sam Houston Parkway North, Suite 300 Houston, Texas 77043 Re: Battalion Oil Corporation Registration Statement on Form S-3 Filed March 18, 2022 File No. 333-263707 Dear Mr. Little: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Cheryl Brown, Law Clerk, at (202) 551-3905 or Karina Dorin, Staff Attorney, at (202) 551-3763 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Jeff M. Dobbs, Esq.