BATTALION OIL CORP

Regulatory Filings • Sep 15, 2021

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www.battalionoil.com ⁞ 3505 West Sam Houston Parkway North, Suite 300, Houston, Texas 77043 ⁞ 832.538.0300

September 15, 2021

VIA EDGAR

U.S. Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation 100 F Street, N.E. Washington, D.C. 20549 Attn: Liz Packebusch

Re:	Battalion Oil Corporation
​	Registration Statement on Form S-3
​	File Number 333-259415

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Battalion Oil Corporation hereby requests that the effectiveness of the above-referenced registration statement on Form S-3 be accelerated so that it will become effective at 4:00 p.m. Eastern time on September 17, 2021, or as soon thereafter as practicable.

Please telephone the undersigned (832-538-0300) or William T. Heller IV of Mayer Brown LLP (713-238-3000) if you have any questions with respect to the foregoing.

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​	Very truly yours,	​	​
​	​
​	BATTALION OIL CORPORATION
​	​
	By:	/s/ Walter Mayer
		Name:	Walter Mayer
		Title:	Vice President, Legal