Mail Stop 4628

                                                            August 14, 2018


Robert M. Roosa
Chief Executive Officer and Director
Brigham Minerals, Inc.
5914 W. Courtyard Drive, Suite 100
Austin, TX 78730

       Re:     Brigham Minerals, Inc.
               Draft Registration Statement on Form S-1
               Submitted July 17, 2018
               CIK No. 0001745797

Dear Mr. Roosa:

       We have reviewed your draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

General

1.     Please supplementally provide us with copies of all written
communications, as defined
       in Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your
       behalf, present to potential investors in reliance on Section 5(d) of
the Securities Act,
       whether or not they retain copies of the communications.
 Robert M. Roosa
Brigham Minerals, Inc.
August 14, 2018
Page 2

Summary, page 1

Prospective Undeveloped Horizontal Drilling Locations, page 6

2.     Expand the disclosure here and elsewhere on page 85 relating to your
prospective
       undeveloped horizontal drilling locations to clearly explain or
illustrate the mathematical
       relationship between the number of gross drilling locations, number of
DSUs and
       assumed gross wells per DSU.

Risk Factors, page 26

We have little to no control over the timing of future drilling..., page 31

3.     Revise your disclosure to remove any figures based on an aggregation of
the individual
       estimates of proved, probable and possible reserves. If you require
further guidance,
       refer to Question 105.01 in the Compliance and Disclosure
Interpretations regarding Oil
       and Gas Rules, available on our website at:

       http://www.sec.gov/divisions/corpfin/guidance/oilandgas-interp.htm

Use of Proceeds, page 55

4.     Please also quantify the net proceeds that you expect to receive if the
underwriters
       exercise in full their option to purchase additional shares from you.

Dividend Policy, page 56

5.     Disclosure here (payment of dividends "if any") and at page 49 regarding
the
       determination "whether" to declare dividends appears to be inconsistent
with your
       assertion at page 19 under the subheading "Dividend policy" where you
state that you
       "expect to pay dividends...." We note also the related disclosure in the
risk factor which
       begins "Brigham Inc. is a holding company" at page 43. Please revise to
reconcile the
       various disclosures.

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
63

Quantitative and Qualitative Disclosure About Market Risk, page 74

Capital Requirements and Sources of Liquidity, page 71

6.     Please quantify your anticipated capital expenditure requirements for
2018. Refer to Item
       303(a) of Regulation S-K.
 Robert M. Roosa
Brigham Minerals, Inc.
August 14, 2018
Page 3

Commodity Price Risk, page 74

7.     You indicate that your credit agreement allows you to hedge up to 85% of
your
       "reasonably anticipated projected production from proved developed
producing
       reserves." We note also the disclosure at page 66 regarding results from
hedging during
       the last two fiscal years. Please quantify the percentage of your
production that you
       hedged during those two years.

Business, page 80

Proved, Probable and Possible Reserves, page 89

8.     The discussion of probable and possible reserves refers to the various
circumstances
       identified in the definitions under Rule 4-10(a)(18) and (a)(17) of
Regulation S-X,
       respectively, where such reserves may be assigned. Expand your
disclosure to further
       explain the extent that one or more of the factors you have identified
apply to the
       probable and possible reserves disclosed in the prospectus. Refer to the
disclosure
       requirements pursuant to Item 1202(a)(5) of Regulation S-K.

PUDs, page 93

9.     The disclosure on page 94 relating to a discussion of your proved
undeveloped reserves
       appears to indicate that you limit your proved "developed reserves" to
the quantities of
       oil and gas that are reasonably certain to be recovered in the next five
years." Review
       and revise your disclosure as may be necessary to be consistent with the
context of the
       discussion.

10.    The disclosure on page 94 indicates that "we generally do not have
evidence of approval
       of our operators' development plans, however we use a probabilistic
approach to define
       and allocate locations to proved reserves." Furthermore, the disclosure
in Exhibit 99.2
       states "The drill schedules for each basin were completed based on spud
and completion
       rates within each basin. First, undeveloped wells with a registered API
number were
       scheduled, followed by wells waiting on completion. Next, wells were
arranged by
       reserve category, with PDNP properties scheduled first, followed by PUD,
PROB and
       POSS properties. Within each reserve category, wells were ordered by
decreasing EUR,
       with the highest EUR wells scheduled first."

       Provide us with a reasonably detailed explanation of the methodology you
use for
       defining and allocating locations to proved reserves. As part of your
explanation, tell us
       how this methodology and the procedure to schedule undeveloped wells as
noted in
       Exhibit 99.2 meet the requirements for proved reserves and reasonable
certainty under
       Rule 4-10(a)(22) and (a)(24), the requirements for an adopted plan and
development
       schedule and the funding for such activities, e.g. by the operator,
under Rule 4-
 Robert M. Roosa
Brigham Minerals, Inc.
August 14, 2018
Page 4

       10(a)(31)(ii) and Rule 4-10(a)(26) of Regulation S-X, respectively, and
the guidance in
       C&DI 131.04.

Productive Wells, page 95

11.    Tell us how you considered the requirement to disclose the total number
of net productive
       wells. Refer to the disclosure requirements under Item 1208(a) of
Regulation S-K. This
       comment also applies to your disclosure of net wells under the section
"Drilling Results"
       pursuant to the disclosure requirements under Item 1205(a) of Regulation
S-K.

Management, page 103

Committees of the Board of Directors, page 105

Audit Committee, page 105

12.    Once known, please update the disclosure in this section to identify the
audit committee
       members and audit committee financial expert.

Executive Compensation, page 106

13.    Please include the information required by Item 402 of Regulation S-K
with your next
       amendment.

14.    Describe the material terms of any employment agreements or arrangements
with your
       named executive officers and file the individual agreements, if any, as
exhibits. For
       guidance, please refer to Item 601(b)(10)(iii)(A) and Instruction 1 to
Item 601(b)(10) of
       Regulation S-K.

Description of Capital Stock, page 122

15.    We note that your description of your capital stock and your charter and
bylaws "is
       qualified in its entirely by reference to the provisions of applicable
law...." You may not
       qualify your disclosure by reference to the "provisions of applicable
law" or other
       information not filed as an exhibit. Please revise your disclosure
accordingly.

Class A Common Stock, page 122

16.    Please revise to identify counsel and attribute to counsel the legal
conclusions that all
       outstanding shares and shares of Class A common stock to be issued upon
completion of
       this offering, are, and will be, "fully paid and non-assessable."
 Robert M. Roosa
Brigham Minerals, Inc.
August 14, 2018
Page 5



Financial Statements, page F-1

17.    You will need to update the historical and pro forma financial
statements prior to the
       effective date of your registration statement to comply with Rule 3-12
and Article 11 of
       Regulation S-X.

Note 3   Oil and Gas Properties, page F-18

18.    Please expand your disclosure regarding the cost of unevaluated
properties to include a
       description of the current status of the significant properties or
projects involved, and the
       anticipated timing of the inclusion of the costs in the amortization
computation, to
       comply with Rule 4-10 (c)(7)(ii) of Regulation S-X.

Oil and Natural Gas Reserves, page F-23

19.    The production figures by individual product type presented for 2016 and
2017 appear to
       be inconsistent with the comparable figures presented elsewhere on pages
69 and 94,
       respectively. Review and revise your disclosure as may be necessary to
resolve this
       inconsistency.

20.    Expand the tabular disclosure of proved reserves to additionally provide
the net quantities
       by individual product type of proved developed and proved undeveloped
reserves at the
       beginning of each of the periods presented, e.g. December 31, 2015.
Refer to the
       disclosure requirements under FASB ASC 932-235-50-4.

21.    There appears to be a lack of correlation between the changes in your
proved
       undeveloped reserves due to extensions and discoveries of 4,708 MBoe and
revisions of
       previous estimates of (1,367) MBoe, as disclosed on page 93, and the
changes in your
       total proved reserves due to extensions and discoveries of 3,259 MBoe
and revisions of
       previous estimates of 172 MBoe, as disclosed on page F-23, for the year
ended December
       31, 2017. Tell us the reason for the apparent inconsistencies in your
disclosure.

22.    Expand the disclosure relating to the changes in total net proved
reserves for each of the
       periods presented to provide an appropriate narrative explanation for
the significant
       changes relating to each line item entry within your reconciliation,
such as revisions of
       previous estimates, improved recovery, extensions and discoveries,
acquisitions and
       divestitures. Your explanation should address the change for the line
item by separately
       identifying and quantifying each factor, including offsetting factors,
that contributed to a
       significant change so that the change in net reserves between periods is
fully explained.
       To the extent that two or more factors contribute to a significant
change, indicate the net
       amount attributable to each factor accompanied by a narrative
explanation. Your
       disclosure of revisions in the previous estimates of reserves in
particular should identify
       such factors as changes caused by commodity prices, well performance,
unsuccessful
 Robert M. Roosa
Brigham Minerals, Inc.
August 14, 2018
Page 6

       and/or uneconomic proved undeveloped locations or the removal of proved
undeveloped
       locations due to changes in a previously adopted development plan.

Exhibits

23.    You indicate that your revolving credit facility will remain in place
following the
       offering. Please file the governing credit agreement as an exhibit to
your registration
       statement. Refer to Item 601(b)(10) of Regulation S-K.

Exhibit 99.1, 99.2

24.    The reserves reports do not appear to include all of the information
that is required by
       Item 1202(a)(8) of Regulation S-K. Please obtain and file revised
reserves reports to
       address the following points:

              State the purpose for which the report was prepared, e.g. for
inclusion as an
              exhibit in a filing made with the U.S. Securities and Exchange
Commission
              (SEC). Refer to the disclosure requirements under Item
1202(a)(8)(i).

              Present the figures for the average realized prices after
adjustments for location
              and quality differentials such as transportation, quality,
gravity and Btu content by
              product type for the reserves included in the report as part of
the primary
              economic assumptions to comply with Item 1202(a)(8)(v).

              Separately present the net quantities, by individual product
type, relating to the
              probable developed and probable undeveloped reserves. Refer to
the
              requirements regarding the optional disclosure of probable
reserves under Item
              1202(a)(2)(iv) and (v) of Regulation S-K.

              Separately present the net quantities, by individual product
type, relating to the
              possible developed and probable undeveloped reserves. Refer to
the requirements
              regarding the optional disclosure of probable reserves under Item
1202(a)(2)(vi)
              and (vii) of Regulation S-K.


25.    Tell us the extent that the 497 gross proved developed non-producing
wells presented in
       "Table I-PDNP" are related to drilled but uncompleted wells ("DUCs"). If
a material
       amount of these reserves are related to DUCs, refer to the definition of
developed oil and
       gas reserves under Rule 4-10(a)(6) of Regulation S-X and tell us how you
determined
       the dollar amount of the remaining development costs in support of the
classification of
       such wells as developed.
 Robert M. Roosa
Brigham Minerals, Inc.
August 14, 2018
Page 7

Closing Comments

        You may contact John Cannarella, Staff Accountant, at (202) 551-3337 or
Karl Hiller,
Accounting Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the
financial statements and related matters. For questions regarding comments on
engineering
matters, you may contact John Hodgin, Petroleum Engineer, at (202) 551-3699.
Please contact
Anuja A. Majmudar, Attorney-Advisor, at (202) 551-3844 or, in her absence,
Timothy S.
Levenberg, Special Counsel, at (202) 551-3707 with any other questions.


                                                          Sincerely,

                                                          /s/ John Reynolds

                                                          John Reynolds
                                                          Assistant Director
                                                          Office of Natural
Resources