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                             May 21, 2024

       Jason Long
       Chief Executive Officer
       LandBridge Company LLC
       5555 San Felipe Street, Suite 1200
       Houston, TX 77056

                                                        Re: LandBridge Company
LLC
                                                            Amendment No. 3 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted May 6,
2024
                                                            CIK No.: 0001995807

       Dear Jason Long:

            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
       March 6, 2024 letter.

       DRS/A filed on May 6, 2024

       Recent Acquisitions, page ii

   1.                                                   We note your disclosure
that in May 2024, you acquired approximately 103,000 surface
                                                        acres from a private
third-party seller which you refer to as the East Line Ranch
                                                        Acquisition. We further
note your references to the Frying Pan Ranch in your Unaudited
                                                        Pro Forma Condensed
Consolidated Financial Statements and the stand alone audited
                                                        financial statements of
Frying Pan Ranch which appear to be related to the same
                                                        acquisition. Please
revise your disclosures throughout your document to consistently refer
                                                        to this acquisition.
 Jason Long
LandBridge Company LLC
May 21, 2024
Page 2
Financial and Operating Data Presentation, page iii

2.       We note your disclosures that the term    pro forma    is used with
respect to financial data
         that refers to the historical financial data of OpCo, as adjusted to
give effect to the East
         Stateline Ranch Acquisition and the Credit Agreement Amendment. We
further note that
         the term "pro forma" is also used when discussing operating data that
refers to the
         historical operating data of OpCo, as adjusted to give effect to the
Acquisitions, in the
         case of data presented as of December 31, 2023, and to the May 2024
Acquisitions, in the
         case of data presented as of March 31, 2024. Given use of the term
"pro forma" is the
         same for both sets of disclosures, please revise the term "pro forma"
to another caption in
         regards to references for operating data throughout the document in
order to avoid
         confusion for readers.
3.       We note your disclosure throughout the filing that presents certain
financial and
         operational data on a pro forma basis. Please include balancing
disclosure throughout your
         amended filing of this data including actual historical amounts.
Summary
Our Assets, page 5

4.       The surface acre totals for the Northern and Southern areas shown in
the illustration titled,
            Overview of our Land Position and WaterBridge   s Infrastructure
Assets    on pages 6 and
         128 appear to be inconsistent with the Northern and Southern surface
acre totals disclosed
         on pages 10-11 and 132. Please review and revise to remove the
inconsistencies.
Our Northern Position, page 10

5.       We refer to your revised disclosure that 8,650 additional surface
acres are leased from the
         BLM and that you have entered into a lease for pipeline right-of-way
rights. Please
         expand your discussion as appropriate to further describe these
arrangements.
Summary Historical and Pro Forma Financial Data, page 39

6.       We note that you are presenting pro forma information for each of the
three categories of
         the cash flow statement for fiscal year 2023. Please tell us the
purpose for including these
         measures. Please also tell us the basis in the SEC rules and
regulations for providing these
         measures as they do not appear to be consistent with the type of pro
forma financial
         information that should be provided pursuant to Article 11-02(c) of
Regulation S-X.
Use of Proceeds, page 86

7.     We refer to your revised disclosures regarding the use of borrowings
under your credit
FirstName LastNameJason Long
       facility incurred within the past year. Please also revise to reference
your other uses, or
Comapany    NameLandBridge
       advise.                  Company
                In this regard, we note on LLC
                                           page 100 that you also refer to
borrowings being used to
May 21,repay
         2024prior
                Pageindebtedness
                      2            and to make a distribution to NDB LLC.
FirstName LastName
 Jason Long
FirstName
LandBridgeLastNameJason
            Company LLCLong
Comapany
May        NameLandBridge Company LLC
     21, 2024
May 21,
Page 3 2024 Page 3
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 101

8.       The oil and gas royalties disclosed in the narrative on page 102
appear to be inconsistent
         with the dollar values provided in the table on page 102. Please
review and revise to
         remove the inconsistencies.
9.       The average realized gas prices disclosed on page 102 (2022 = $6.77
and 2023 = $2.34)
         appear to be inconsistent with the average realized gas prices on page
163 (2022 = $6.36
         and 2023 = $1.67). Please review and revise to remove the
inconsistencies.
Business
Oil, Natural Gas and NGLs Production Prices and Costs
Acreage, page 164

10.      Your response to prior comment 15 in your response letter, dated
February 14, 2024,
         stated you would provide a historical break-out of acreage on a
gross/net developed and
         undeveloped basis in a subsequent filing. As a reminder, please
provide a completed table
         showing the gross/net developed, undeveloped, and total acres as of
December 31, 2023
         and 2022.
11.      We note the table values presented for net mineral acres are based on
a standardized
         1/8th interest. Please expand the table to additionally present your
net mineral acres on an
         actual basis.
Unaudited Pro Forma Condensed Consolidated Financial Statements, page F-5

12.      We note your unaudited pro forma condensed consolidated financial
statements include
         the pro forma impact of the pending acquisition of the East Stateline
Ranch Assets. In
         your disclosures, it appears that you have included the entire amount
of the fair value of
         the assets acquired of $360 million net of the historical equity value
of $12.8 million as an
         adjustment to property plant and equipment, net of accumulated
depreciation on the pro
         forma condensed consolidated balance sheet. We further note that there
does not appear to
         be any transaction adjustments that have been recorded related to such
acquisition on your
         pro forma consolidated statement of operations. Please tell us how the
Company applied
         the guidance in Rule 11-02(a)(6)(i) which requires the Company to
depict the adjustments
         in the pro forma condensed balance sheet in accordance with US GAAP.
Given that it
         appears that such acquisition will be accounted for as a business
combination under ASC
         805, it would appear a preliminary purchase price allocation depicting
the
         anticipated acquired components should be reflected in your pro forma
consolidated
         balance sheet. In addition, the Company should include the impact of
such transaction
         adjustments in its pro forma condensed statement of operations.
 Jason Long
FirstName
LandBridgeLastNameJason
            Company LLCLong
Comapany
May        NameLandBridge Company LLC
     21, 2024
May 21,
Page 4 2024 Page 4
FirstName LastName
Unaudited Pro Forma Condensed Consolidated Statement of Operations for the Year
Ended
December 31, 2022, page F-9

13.      We note that you continue to present a pro forma consolidated
statement of operations for
         the year ended December 31, 2022. You should only present a pro forma
consolidated
         statement of operations for the most recent fiscal year, which in this
case is December 31,
         2023. Please revise to remove your pro forma consolidated statement of
operations for the
         year ended December 31, 2022. See Article 11-02(c)(2).
DBR Land Holdings LLC and Subsidiaries
Notes to Consolidated Financial Statements
Analysis of Changes in Proved Reserves, page F-41

14.      The detailed explanations of the changes in proved reserves that
occurred during the years
         ended December 31, 2022 and December 31, 2023, which were included in
Submission
         No. 3, were removed from Submission No. 4. Please revise your future
submission to
         include these detailed explanations.
Exhibits

15.      We note the revised disclosures regarding a new produced water
facilities agreement and a
         fresh water facilities agreement with WaterBridge. Please revise your
exhibit index to
         include such agreements, or advise.
16.      The disclosures in Exhibits 99.1 to 99.2 do not appear to address all
of the reserve
         report requirements pursuant to Item 1202(a)(8) of Regulation S-K or
refer to definitions
         and requirements other than those specified in Rule 4-10(a) of
Regulation S-X. Please
         obtain and file revised reserve reports to address the following
points:

                Expand the disclosure to specify the initial benchmark and the
average realized prices
              after adjustments for location and quality differentials for each
product type
              represented in the report including natural gas liquids to comply
with Item
              1202(a)(8)(v) of Regulation S-K.

                Remove all references to definitions and requirements other
than those as identified
              in Rule 4-10(a) of Regulation S-X. For example the disclosure on
page 1 and
              elsewhere on page 2 under the section    Reporting Requirements
 indicate the
              determination and classification of the proved undeveloped
locations and the reserves
              included in the reports have been prepared in accordance with the
guidelines,
              definitions and requirements established by the Society of
Petroleum Engineers
              (   SPE   ) or as set forth in the Petroleum Resources Management
System.
 Jason Long
FirstName
LandBridgeLastNameJason
            Company LLCLong
Comapany
May        NameLandBridge Company LLC
     21, 2024
May 21,
Page 5 2024 Page 5
FirstName LastName
General

17.      We note that you have added photographs after the cover page. While
         graphic presentations or images are generally permitted in
registration statements, the
         graphic presentations must accurately represent the registrant's
current business. For
         example, it is not appropriate to include graphics that do not
accurately depict your current
         business. Accordingly, please revise as appropriate to address
graphics that depict
         potential future uses of your property (e.g., as a data center). Refer
to Securities Act
         Forms C&DI 101.02.
       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,

                                                               Division of
Corporation Finance
                                                               Office of Real
Estate & Construction
cc:      David Oelman, Esq.