August 15, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Energy and Transportation

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Irene Barberena-Meissner

 

Re:	APA Corporation

Registration Statement on Form S-4

Filed August 8, 2025

File No. 333-289400

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, APA Corporation hereby requests acceleration of the effective date of its Registration Statement on Form S-4 (File No. 333-289400) (the “Registration Statement”). We respectfully request that the Registration Statement become effective as of 10:00 a.m., Washington, D.C. time, on August 19, 2025, or as soon as practicable thereafter.

Please contact Troy Harder, of Bracewell LLP, counsel to the Company, at (713) 221-1456, if you have any other questions or concerns regarding this request. In addition, please notify Mr. Harder by telephone when this request for acceleration has been granted.