May 9, 2019

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

       Re: Roan Resources, Inc.
           Amendment No. 3 to Registration Statement on Form S-1
           Filed May 3, 2019
           File No. 333-227953

Dear Mr. Edwards:

       We have reviewed your 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.

Form S-1/A filed May 3, 2019

Description of Capital Stock
Forum Selection, page 132

1.     We note your revised disclosure regarding your exclusive forum
provision. Please clearly
       state whether this provision is intended to apply to actions arising
under the Securities Act
       or Exchange Act, or tell us why you cannot provide such statement.
Please refer to
       comment 3 in our letter dated February 21, 2019, and comment 18 in our
letter dated
       November 19, 2018.
        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.
 David Edwards
Roan Resources, Inc.
May 9, 2019
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 with
questions
about engineering comments. You may contact Jenifer Gallagher, Staff
Accountant, at (202)
551-3706 or John Cannarella, Staff Accountant, at (202) 551-3337 if you have
questions
regarding comments on the financial statements and related matters. Please
contact Parhaum J.
Hamidi, Attorney-Advisor, at (202) 551-3421 or Loan Lauren Nguyen, Legal Branch
Chief, at (202) 551-3642 with any other questions.



FirstName LastNameDavid Edwards                            Sincerely,
Comapany NameRoan Resources, Inc.
                                                           Division of
Corporation Finance
May 9, 2019 Page 2                                         Office of Natural
Resources
FirstName LastName