September 23, 2024

Zack Arnold
Chief Executive Officer
Infinity Natural Resources, Inc.
2605 Cranberry Square
Morgantown, WV 26508

        Re: Infinity Natural Resources, Inc.
            Amendment No. 2 to Draft Registration Statement on Form S-1
            Submitted September 9, 2024
            CIK No. 0002029118
Dear Zack Arnold:

     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
August 30, 2024 letter.

Amendment No. 2 to Draft Registration Statement on Form S-1
Summary, page 4

1.      Please revise your prospectus to define "Enverus" at first usage and to
provide
        the information about Enverus and your agreement that appears in the
first two paragraphs
        of your response to prior comment 5.
 September 23, 2024
Page 2
Prospectus Summary
Summary Reserve, Production and Operating Data
Summary Reserve Data, page 28

2.     Please expand the disclosure of your proved reserves to additionally
present the proved
       undeveloped reserves by individual product type. Refer to the disclosure
requirements in
       Item 1202(a)(2)(ii) of Regulation S-K.
Business
Reserve Data and Presentation
Proved Undeveloped Reserves, page 113

3.     Please further expand your disclosure of the material changes to proved
undeveloped
       reserves during 2023 to explain the positive 1.2 MMBoe revision. Refer
to Item 1203(b)
       of Regulation S-K.

       This comment also applies to the positive 1.2 MMBoe revision to previous
estimates in
       total proved reserves on page F-49.

       Additionally, we note your discussion of revisions on page F-14 for the
nine months
       ended September 30, 2023 for both URV and PEO and the discussion on page
F-86 for
       the years ended December 31, 2021 and 2022 identifies two separate and
unrelated factors
       contributing to the change, e.g. upward revisions for prices, partially
offset by downward
       revisions associated with well forecasting. Please expand your
discussion to separately
       quantify each factor, such that the change to the line item is fully
explained. Refer to the
       disclosure requirements in FASB ASC 932-235-50-5.

Acreage as of December 31, 2023, page 117

4.     We note your gross and net acreage table is based on acres by horizon.
Please revise your
       disclosure to present the Company's acreage in terms of surface acreage,
so that no acre is
       duplicated. Refer to the disclosure requirements in Item 1208 of
Regulation S-K.
Undeveloped Acreage Expirations as of December 31, 2023, page 117

5.     We note your disclosure of 14.6 MBoe of proved undeveloped reserves
associated
       with potentially expiring acreage. Please clarify the units for this
volume are MBoe and
       not MMBoe.
Notes to the Unaudited Pro Forma Condensed Consolidated Financial Statements
Note 1-Basis of Presentation and Description of Transactions, page F-7

6.     As stated in your response to prior comment 22, please revise to
disclose that Natural
       Resources LLC ("INR Holdings") will be a VIE and you will be the primary
beneficiary
       of INR Holdings. Revise to disclose the basis for consolidation of INR
Holdings,
       specifically the significant judgments and assumptions made in
determining that INR
       Holdings must be consolidated and provide the disclosures required by
ASC 810-10-50-
       2AA, 2AB and 50-3. Please ensure to include the disclosures here, pages
138, F-19 and F-
       21.
 September 23, 2024
Page 3

Note 4-Transaction Accounting Adjustment, page F-9

7.     We note your response to prior comment 28. Please show us how the
adjustment
       discussed in note 4(l) regarding the addition of $0.5 million unrealized
gain that was
       previously included in URV   s other comprehensive income is reflected
here and revise
       your disclosures as appropriate.
Notes to Consolidated Financial Statements
Note 15-Supplemental Information on Oil and Natural Gas Producing Activities
(Unaudited)
Standardized Measure of Discounted Future Net Cash Flows, page F-49

8.     We note the table presenting the calculation of the standardized measure
of discounted
       future net cash flows at the top of page F-50 appears unchanged. We
re-issue the prior
       comment 37.
Supplementary Oil and Gas Disclosures
Net Proved Developed and Undeveloped Oil and Gas Reserves, page F-107

9.     We note the arithmetic summation of the individual line items for proved
developed
       reserves and proved undeveloped reserves presented at December 31, 2020
are
       inconsistent with the total net proved developed and undeveloped
reserves shown in the
       first line of the table on page F-107. Please revise your disclosure to
remove the
       inconsistence.
Exhibits

10.    We note that your response to prior comment 38 suggests in part that the
49% customer is
       "easily replaceable." However, your risk factor disclosure at page 39
indicates: "If this
       purchaser [is unable to satisfy its] contractual obligations, we may be
unable to sell such
       production to other customers on terms we consider acceptable." Please
revise to
       reconcile these disclosures, and file all material contracts as exhibits
to the registration
       statement pursuant to Item 601(b)(10) of Regulation S-K.
       Please contact Brian McAllister at 202-551-3341 or Raj Rajan at
202-551-3388 if you
have questions regarding comments on the financial statements and related
matters. You may
contact Sandra Wall at 202-551-4727 or John Hodgin at 202-551-3699 with
questions regarding
engineering comments. Please contact Cheryl Brown at 202-551-3905 or Timothy
Levenberg at
202-551-3707 with any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Energy &
Transportation
cc:   Matthew R. Pacey, Esq.