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                             November 16, 2020

       Jeffrey L. Ritenour
       Executive Vice President and Chief Financial Officer
       Devon Energy Corporation
       333 West Sheridan Avenue
       Oklahoma City, Oklahoma 73102-5015

                                                        Re: Devon Energy
Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed February 19,
2020
                                                            File No. 001-32318

       Dear Mr. Ritenour:

              We have reviewed your filing 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2019

       Business and Properties
       Proved Reserves, page 8

   1.                                                   To the extent that you
disclose material additions to your proved reserves, expand your
                                                        disclosure to provide a
general discussion of the technologies used to establish the
                                                        appropriate level of
certainty for your reserves estimates. Refer to Item 1202(a)(6) of
                                                        Regulation S-K.
       Notes to Consolidated Financial Statements
       Note 21-Supplemental Information on Oil and Gas Operations (Unaudited)
       Proved Reserves, page 96

   2.                                                   The explanation for the
changes that occurred in total proved reserves indicates that a
                                                        portion of the change
attributed to extensions and discoveries for fiscal 2018 and 2017
 Jeffrey L. Ritenour
Devon Energy Corporation
November 16, 2020
Page 2
         was the result of infill drilling. Refer to subparagraphs (a) and (d)
of FASB ASC 932-
         235-50-5 and tell us your rationale for classifying reserves resulting
from drilling an infill
         well as an extension.
3.       The change in the total net quantities of proved reserves attributed
to extensions and
         discoveries appears to be significantly greater than the corresponding
change in the net
         quantities of proved undeveloped reserves for each of the last three
fiscal years presented,
         e.g. a difference of 71 MMBoe or 44% between the 160 MMBoe change
attributed to total
         proved reserves and the 89 MMboe change attributed to proved
undeveloped reserves for
         the period ending December 31, 2019. Expand the discussion of the
significant changes
         that occurred in your total proved reserves attributed to extensions
and discoveries to
         explain the reason(s) for these differences. Refer to FASB ASC
932-235-50-5.
Proved Undeveloped Reserves, page 97

4.       Expand the discussion of the changes that occurred in your proved
undeveloped reserves
         to include an explanation of the material change due to revisions
other than price. Your
         explanation should address the overall change for the line item by
separately identifying
         and quantifying the net amount attributable to each factor that
contributed to the change,
         including offsetting factors, so that the change in net proved
undeveloped reserves
         between periods is fully reconciled.

         In particular, disclosure relating to revisions in previous estimates
for reasons other than
         price should identify such individual underlying factors as changes
caused by well
         performance, improved recovery, or changes resulting from the removal
of proved
         undeveloped locations due to changes in a previously adopted
development plan. Refer to
         the disclosure requirements in Item 1203(b) of Regulation S-K.
        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.

       You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 if
you have
questions regarding the comments. Please contact Craig Arakawa, Branch Chief,
at (202) 551-
3650 with any other questions.



FirstName LastNameJeffrey L. Ritenour                           Sincerely,
Comapany NameDevon Energy Corporation
                                                                Division of
Corporation Finance
November 16, 2020 Page 2                                        Office of
Energy & Transportation
FirstName LastName