October 16, 2024

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

        Re: Infinity Natural Resources, Inc.
            Registration Statement on Form S-1
            Filed October 4, 2024
            File No. 333-282502
            _
            Amendment No. 3 to Draft Registration Statement on Form S-1
            Submitted September 27, 2024
            CIK No. 0002029118
Dear Zack Arnold:

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

        Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, references to prior comments are to our September 23, 2024 letter.

Registration Statement on Form S-1
Certain Relationships and Related Party Transactions, page 150

1.     We note that the newly filed form of tax receivable agreement (exhibit
10.4) provides
       for the possibility of accelerated cash payments to your CEO, CFO, and
other related
       persons. Please expand the disclosure in the first paragraph on page 58
and also in the
       subsection "Tax Receivable Agreement" at page 151 to quantify in each
case the
       potential amounts of estimated lump-sum payments to each such related
person. See
       Item 404(a) of Regulation S-K.
 October 16, 2024
Page 2

Exclusive Forum, page 156

2.     We note that Section 10.6 of the newly filed form of amended charter
(exhibit 3.3)
       provides in part that "the federal district courts of the United States
of America shall
       be the sole and exclusive forum for the resolution of any complaint
asserting a cause
       of action arising under the Securities Act or the Exchange Act." Please
expand the
       disclosure at page 156 to note that Section 22 of the Securities Act
creates concurrent
       jurisdiction for federal and state courts over all suits brought to
enforce any duty or
       liability created by the Securities Act or the rules and regulations
thereunder.
Report of Independent Registered Public Accounting Firm, page F-18

3.     Please amend your registration statement to have your auditor remove the
language in
       the third paragraph which states "and in accordance with auditing
standards generally
       accepted in the United States of America." Please refer to PCAOB
Auditing Standard
       3101. This comment also applies to audit report on Infinity Natural
Resources, LLC
       included in page F-23.
Exhibits

4.     We note your response to prior comment 10. Please revise your prospectus
to make
       clear, as you stated in your letter, that the contract with the 49%
customer is only for
       six months and is not a contract on which your business is substantially
dependent.
        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.

       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. 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.