TPLTexas Pacific Land Corporation

Please expand your filing to include a summary of your oil and gas reserves at fiscal year-end. Refer to the disclosure requirements in Items 1202(a)(1) through 1202(a)(4) of Regulation S-K.

The Company acknowledges the

Staff’s comment and respectfully advises that the Company intends to include the requested information in “Item 2. Properties” in its Form 10-K for the fiscal year ending December 31, 2025, which the Company expects to file with the Commission in February 2026.

Please see the section titled “Summary of Estimated Proved Developed Producing (“PDP”) Reserves” in the attached

Annex B for an example of the Company’s planned disclosure. Read in the reply ↗

We note that you have not previously disclosed reserves estimates in a filing with the Commission and that you are disclosing material additions to your reserves estimates. Accordingly, explain to us how you considered providing a general discussion of the technologies used to establish the appropriate level of certainty for reserves estimates from material properties included in the total reserves disclosed.

Rest of the question

See Item 1202(a)(6) Disclose and describe the internal controls you use in your reserves estimation effort. In addition, disclose the qualifications of the technical person primarily responsible for overseeing the preparation of the reserves estimates and, if you represent that a third party conducted a reserves audit, disclose the qualifications of the technical 3. person primarily responsible for overseeing such reserves audit. See Item 1202(a)(7) 4. Expand your disclosure to include total gross and net productive wells, expressed separately for oil and gas, associated with your interests. Refer to the disclosure requirements in Item 1208(a) of Regulation S-K. 5. Please expand your acreage disclosure to provide a break-out of gross and net developed and undeveloped acreage. Refer to the disclosure requirements in Item 1208(b) of Regulation S-K. Management's Discussion and Analysis of Financial Condition and Results of Operations Year Ended December 31, 2024 Compared to Year Ended December 31, 2023 Land and Resource Management, page 26 6. Please expand your disclosure to provide the last three fiscal years of production and average sales prices. Refer to the disclosure requirements in Item 1204 of Regulation S-K. Non-GAAP Performance Measures, page 27 We note your presentation of a non-GAAP financial measure titled 'Free Cash Flow'. Please address the following: • You identify Free Cash Flow as performance measure, but the label suggests it may be a liquidity measure. Tell us the specific facts and circumstances that led you to conclude this is a performance measure. If you continue to believe Free Cash Flow is a performance measure, tell us how you determined it is appropriate to exclude cash-based adjustments in the calculation of a performance measure. Refer to Questions 100.01 and 100.05 of the Non-GAAP Financial Measures C&DI's. • Regardless of whether you conclude Free Cash Flow is a performance or liquidity measure, please revise your non-GAAP reconciliation to reconcile the measure to the most directly comparable GAAP measure, rather than presenting a "compound" reconciliation from Net Income to Adjusted EBITDA then to Free Cash Flow. • Please disclose the reasons why you believe Free Cash Flow provides useful information to investors and any additional purposes for which management uses this measure. Refer to Items 10(e)(1)(i)(C) and (D) of Regulation S-K. • Finally, we note you define Free Cash Flow as Adjusted EBITDA less current income tax expense and capital expenditures. Per your consolidated Statement of Cash Flows, Cash flows from investing activities, total capital expenditures (excluding acquisitions of a business) appears to be $426.7 million ($395,577 + $1,476 + $29,696). Please revise your reconciliation accordingly, or tell us why the amount presented in the reconciliation differs from this amount, and explain the differences. 7. This comment also applies to your Forms 10-Q and earnings releases. Supplemental Oil and Gas Reserve Information (Unaudited) Analysis of Changes in Oil and Natural Gas PDP Reserves, page F-32 8. We note your disclosure on page 3 that the average realized price received per Boe during the year 2024 decreased 6.4% from the year 2023; however, the reconciliation of the changes in proved reserves during 2024 does not include a negative revision due to prices. Please review and revise your disclosure to identify and quantify the net amount of change due to the decrease in commodity prices, and any other contributing factors, including offsetting factors, so the change due to revisions of prior estimates is fully explained. Refer to the disclosure requirements in FASB ASC 932-235-505(a). 9. Please expand the disclosure of the net developed reserves appearing below the table of changes in estimated reserves to include the volumes as of the beginning of the earliest period presented, i.e. as of December 31, 2021. Refer to the disclosure requirements in FASB ASC 932-235-50-4.

To establish reasonable certainty for its estimated proved reserves, the technologies and economic data used in the estimation included actual production data, downhole completion information, geologic data, and historical well cost and operating expense data. The Company intends to include the requested information in “Item 2. Properties” in its Form 10-K for the fiscal year ending December 31, 2025, which the Company expects to file with the Commission in February 2026.

Rest of the answer

Please see the section titled “Proved Reserves Evaluation and Review of Estimated

Proved Producing Reserves” in the attached Annex B for an example of the Company’s planned disclosure.

Read in the reply ↗