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                             March 6, 2024

       Steven R. Jones
       Co-Chief Executive Officer
       LandBridge Co LLC
       5555 San Felipe Street, Suite 1200
       Houston, TX 77056

                                                        Re: LandBridge Co LLC
                                                            Amendment No. 2 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted February
14, 2024
                                                            CIK No.: 0001995807

       Dear Steven R. Jones:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              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 a comment applies 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 this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional
       comments. Unless we note otherwise, any references to prior comments are
to comments in our
       January 9, 2024 letter.

       Draft Registration Statement on Form S-1 Submission No. 3

       Organizational Structure, page 25

   1.                                                   We note your revised
disclosures and response to prior comment 4. As previously stated,
                                                        please confirm that all
information regarding your reorganization, including the
                                                        approximate anticipated
ownership split, will be provided pre-effectively, and revise your
                                                        disclosures as
appropriate, including by expanding your summary to add balancing
                                                        disclosures to state
the amount of NBD Parent's estimated equity interest in OpCo and to
                                                        further describe the
control that NDB Parent will have and the conflicts of interest.
 Steven R. Jones
FirstName
LandBridgeLastNameSteven R. Jones
            Co LLC
Comapany
March      NameLandBridge Co LLC
       6, 2024
March2 6, 2024 Page 2
Page
FirstName LastName
Risk Factors
Our Proved Undeveloped Reserves, page 46

2.       The figures for the total proved reserves of 2,425 MBoe and the
percentage of proved
         developed reserves of 66.1% as of September 30, 2023 appear to be
inconsistent with the
         comparable figures for total proved reserves and the percentage
calculated using the
         proved developed reserves disclosed elsewhere on pages 155 and F-39.
Please revise your
         disclosure to resolve these inconsistencies or tell us why a revision
is not needed.
Risk Factors
Our customers's operations on our land may be exposed. . ., page 58

3.       We acknowledge your revised disclosures in response to prior comment
8. Please also
         revise the heading of this risk factor to explain the risk that you
may be subject to strict,
         joint and several liability for spills or contamination on your
properties, even if you do not
         have any control over the relevant activities on your properties.
Industry
Hydrocarbon Value Chain, page 112

4.       We have read your response to prior comment 6 and note your revised
presentation of the
         "identified well locations" according to NSAI as of September 25,
2023; however, these
         locations are presented as "Development Locations" in the table on
page 112 and in the
         sentence prefacing the table. If all of these identified locations
cannot be classified as
         development wells pursuant to the meaning in Rule 4-10(a)(9) of
Regulation S-X, please
         revise to remove the term development.
Customers; Material Contracts and Marketing, page 141

5.       We note your revised disclosures and response to prior comment 8.
Please expand your
         disclosures with respect to each type of agreement to further describe
the economic terms
         for each type of agreement. For example, we note your reference to
posted UL prices and
         that you state you use such prices for reference in establishing your
own prices. Please
         expand your discussion of how your prices relate to the UL prices you
disclose. We also
         note, for example, that you state that your SURAs and SUAs generally
provide for
         automatic annual increases in royalties that are tied to the CPI or
are negotiated on a case-
         by-case basis, and that your resource royalty agreements involve fees
that are negotiated
         on a case-by-case basis. Revise to provide additional information,
such as by using royalty
         ranges, or explaining when agreements may deviate from having
royalties tied to the CPI,
         to provide investors with additional context regarding the economic
terms of your material
         agreements.
 Steven R. Jones
FirstName
LandBridgeLastNameSteven R. Jones
            Co LLC
Comapany
March      NameLandBridge Co LLC
       6, 2024
March3 6, 2024 Page 3
Page
FirstName LastName
Executive Compensation, page 167

6.       We note your revised disclosures, including that you deleted the name
of one of your
         named executive officers, even though you state that you are required
to disclose the
         compensation for your principal executive officer and two most highly
compensated
         executive officers. Please revise to update this section for the 2023
compensation for each
         of your named executive officers, or otherwise explain.
Index to Financial Statements
LandBridge Company LLC , page F-1

7.       Please amend your filing to update your financial statements and other
financial
         information in accordance with Rule 8-08 of Regulation S-X.
Notes to the Consolidated Financial Statements
14. Supplemental Oil and Gas Information (Unaudited)
Analysis of Changes in Proved Reserves, page F-39

8.       We note the revised NGL production and total production for the nine
months ended
         September 30, 2023; however, the net proved reserves reconciliation on
page F-39
         incorrectly shows total production for the first nine months of 2023
as a positive value.
         Please revise this volume to a negative value.
Exhibits

9.       We note the consent previously filed as Exhibit 23.4 from W.D. Von
Gonten, regarding
         the reports dated December 31, 2022 and September 30, 2023, has been
removed. Please
         revise your disclosure to ensure that you have satisfied all of the
applicable requirements
         for third party consents or tell us why a revision is not needed.
10.      We have reviewed the revised disclosures in Exhibits 99.2 and 99.3 and
note additional
         and associated disclosure issues. Please obtain and file revised
reserve reports to address
         the following points as part of the primary economic assumptions that
are required to be
         disclosed pursuant to Item 1202(a)(8)(v) of Regulation S-K:

                The average benchmark prices for oil and gas are incorrectly
labeled as "average
              realized prices." "Average realized prices" are the average
prices after the adjustment
              for price differentials.
                The reports indicate that operating expenses and capital costs
were considered as part
              of the evaluation to "establish economic producibility," but the
discussion does not
              additionally clarify that since the Company's ownership interests
consist of only
              mineral/royalty interests, these costs are not paid by the
Company, and therefore are
              not deducted from the estimated future cash flows.
                The reports indicate that abandonment costs were considered as
part of the
              evaluation, but the discussion does not additionally clarify that
since the Company's
 Steven R. Jones
LandBridge Co LLC
March 6, 2024
Page 4
           ownership interests consist of only mineral/royalty interests, these
costs are not paid
           by the Company, and therefore are not deducted from the estimated
future cash flows.
           Also, please note that abandonment costs are incurred after the
economic limit is
           reached, and therefore are not considered in establishing the
economic
           producibility.    Please revise the disclosure accordingly.
             We also note the disclosure under the section    Projections    on
page 2 of the reports
           appears to include a reference to additional supplemental
information, e.g. "attached
           reserves and revenue projections." The reports as filed do not
appear to include any
           separate attachments. Please obtain and file revised reports to
include the referenced
           supplemental information. Alternatively, remove this reference if
you do not intend to
           include this supplemental information.

       Please contact Ameen Hamady at 202-551-3891 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Catherine De Lorenzo at 202-551-3772 or Dorrie Yale at 202-551-8776
with any other
questions.



                                                            Sincerely,
FirstName LastNameSteven R. Jones
                                                            Division of
Corporation Finance
Comapany NameLandBridge Co LLC
                                                            Office of Real
Estate & Construction
March 6, 2024 Page 4
cc:       David Oelman, Esq.
FirstName LastName