June 24, 2025

Ronald Glass
Vice President and Chief Accounting Officer
Kosmos Energy Ltd.
8176 Park Lane
Dallas, Texas 75231

       Re: Kosmos Energy Ltd.
           Form 10-K for the Fiscal Year ended December 31, 2024
           Filed February 24, 2025
           File No. 001-35167
Dear Ronald Glass:

       We have reviewed your filing and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year ended December 31, 2024
Financial Statements
Note 15 - Commitments and Contingencies, page 116

1.     We note your disclosure indicating that you do not believe the outcome
of litigation,
       regulatory examinations and administrative proceedings in which you are
involved
       would have a material effect, either individually or in the aggregate,
with regard to
       your financial position, although could have a material adverse effect
on your results
       of operations. We also see that on pages 42, 54, 55, and 57, you have
disclosures
       concerning possible adverse effects arising from disagreements with host
       governments, contractual counterparties, non-compliance with laws,
regulations and
       other legislative instruments, and your handling of regulated or
hazardous substances.

       For example, you identify various potential liabilities associated with
your operations
       in Ghana, including the release of drilling fluids in its territorial
waters, issues
       regarding approval disputes over the sale of assets, PODs for certain
offshore
       discoveries, and exploration areas that may need to be reliquished, in
addition to taxes
       and other payments that may be due in that jurisdiction.You indicate
there are
 June 24, 2025
Page 2

       unresolved issues that could have a material adverse effect. You also
indicate that if
       you do not adhere to various legal requirements in Ghana, such as the
Petroleum
       Revenue Management Act, Petroleum Commission Act, and Ghanaian Petroleum
       Law, this could result in the suspension or termination of your
operations,
       administrative, civil and criminal penalties, and a material adverse
effect on your
       financial condition and results of operations.

       Please expand your disclosures to describe the nature of the specific
matters for which
       accruals have been made, or for which a material loss in excess of any
accrual is
       reasonably possible, and to include an estimate of the possible loss or
range of loss, to
       comply with FASB ASC 450-20-50-3 and 4. However, if you are not able to
estimate
       your exposure, provide a statement to that effect and disclose the
amounts being
       sought by the counterparty or clarify if there has been no such
quantification.

       In addition to the clarifying disclosures that you propose, provide us
with further
       information as necessary to understand how you have addressed each
matter for which
       you have indicated resolution may yield material adverse effects, to
include your
       assessment of the likelihood of loss, the extent of any accounting
applied, the periods
       impacted by any accruals, claims made by the counterparties and the
reasons you are
       unable to estimate your exposure in each instance, if this is the case.


        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 Robert Babula at 202-551-3339 or Karl Hiller at
202-551-3686 if you
have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation