Mail Stop 4628
                                                           April l, 2019

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

       Re:    Brigham Minerals, Inc.
              Registration Statement on Form S-1
              Response dated March 27, 2019
              File No. 333-230373

Dear Mr. Roosa:

      We have reviewed your March 27, 2019 correspondence 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.

Pro Forma Financial Statements, page F-2

2. Pro Forma Adjustments and Assumptions, page F-8

(a)

1.     We note your disclosure indicating that Brigham LLC will repay
outstanding borrowings
       under the credit facility of $175 million as of December 31, 2018.
Please reconcile this
       detail with the pro forma adjustment showing a repayment of $168.5
million of long-term
       debt and $2.2 million of current portion of debt.

2.     We note that you present a $38.8 million pro forma increase in cash
equivalents as
       adjustment (a). Please expand the corresponding note to your pro forma
financial
       statements to quantify and distinguish between the cash and non-cash
items discussed to
       more clearly indicate the composition of this adjustment.
 Robert M. Roosa
Brigham Minerals, Inc.
April 1, 2019
Page 2


3.     Given your disclosures on pages 59 and 62, indicating borrowings under
your credit
       facility have increased to $185 million subsequent to year-end, please
expand your pro
       forma disclosures to describe any material effects associated with this
change and any
       other changes that are not currently reflected in the pro forma
presentation.

 (d)

4.     We note that you classified the non-controlling interest in Brigham LLC
as a component
       of permanent equity. We also note that the redemption rights of the unit
holders outlined
       on page 16 include the possibility of receiving cash in lieu of Class A
common stock in a
       redemption scenario. Given the organizational chart on page 17, showing
that existing
       owners will have a controlling interest in Brigham Minerals, Inc., and
thereby an indirect
       controlling interest in Brigham Minerals Holdings, LLC, tell us how you
have considered
       their ability to opt for cash redemption via their controlling interests
in applying the
       guidance in FASB ASC 480-10-S99-3A, and classifying the non-controlling
interest
       within permanent equity.

        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.

       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 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. Please contact Karina Dorin, Staff
Attorney, at (202)
551-3763 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