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                             May 20, 2022

       Neal D. Shah
       Senior Vice President and Chief Financial Officer
       Kosmos Energy Ltd.
       8176 Park Lane, Suite 500
       Dallas, Texas 75231

                                                        Re: Kosmos Energy Ltd.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2021
                                                            Filed February 28,
2022
                                                            File No. 001-35167

       Dear Mr. Shah:

              We have reviewed your May 10, 2022 response to our comment letter
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 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.
       Unless we note otherwise, our references to prior comments are to
comments in our April 28,
       2022 letter.

       Form 10-K for the Fiscal Year ended December 31, 2021

       Business
       Operations by Geographic Area, page 13

   1.                                                   We have read your
response to prior comment 1 and note that you propose to disclose
                                                        volumes of production
and average sales prices and costs by geographic area/field on an
                                                        aggregated basis, for
oil/condensate, natural gas liquids and natural gas combined.

                                                        We also note from your
response to prior comment 2 that you propose to discontinue
                                                        reporting natural gas
liquids production and the corresponding average sales prices in your
                                                        Results of Operations
disclosure on page 69.
 Neal D. Shah
FirstName  LastNameNeal D. Shah
Kosmos Energy   Ltd.
Comapany
May        NameKosmos Energy Ltd.
     20, 2022
May 20,
Page 2 2022 Page 2
FirstName LastName
         While we do not object to your aggregation of reserve information
based on the relative
         significance of the reserves we believe that separate disclosure of
production
         volumes, average sales prices and costs by final product sold is
nevertheless required by
         Items 1204(a) and (b)(1) of Regulation S-K. We reissue prior comment
1.
Our Reserves
Summary of Oil and Gas Reserves, page 21

2.       We understand from your response to prior comment 2 that you prefer
not disclosing
         natural gas liquids reserve information separately because you regard
these quantities to
         be immaterial as a proportion of total proved reserves for the years
ended December 31,
         2021, 2020, and 2019. Please expand your disclosures on pages 21 and
125 to include
         your justification for aggregating natural gas liquids and crude
oil/condensate reserves.
3.       We have read your response to prior comment 6 and note your proposed
disclosure
         revisions appear to be limited to changes in your total proved
reserves. Please further
         revise your intended disclosures to also address changes in your
proved undeveloped
         reserves to comply with Item 1203(b) of Regulation S-K, as previously
advised.
Gross and Net Undeveloped and Developed Acreage, page 25

4.       We understand from your response to prior comment 8 that you will
revise your
         disclosure under this heading to include details about the expiration
dates and acreage for
         material concentrations of your undeveloped properties by geographic
area. Please
         provide us with an illustration of your proposed disclosure revisions.
Supplemental Oil and Gas Data (Unaudited)
Net Proved Developed and Undeveloped Reserves, page 125

5.       We have read your response to prior comment 6 and note that change
volumes in the table
         titled "Net Proved Developed and Undeveloped Reserves" on page 125 are
shown by
         individual product type by geographical area, using units of MMBbls
and Bcf, while your
         explanations of these changes reference units of BOE by geographical
area.

         As a result, the changes identified in your discussion cannot be
compared directly to the
         line items in the reserves reconciliation. Please further modify your
intended explanations
         to utilize or additionally include units corresponding to those
reflected in the tabulation.

         Tell us what consideration you have given to enhancing your disclosure
by providing
         additional detail by geographic area as BOE amounts.
 Neal D. Shah
Kosmos Energy Ltd.
May 20, 2022
Page 3

       You may contact Sandra Wall, Petroleum Engineer, at (202) 551-4727 or
John Hodgin,
Petroleum Engineer, at (202) 551-3699 if you have any questions regarding the
comments.



FirstName LastNameNeal D. Shah                          Sincerely,
Comapany NameKosmos Energy Ltd.
                                                        Division of Corporation
Finance
May 20, 2022 Page 3                                     Office of Energy &
Transportation
FirstName LastName