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                 November 16, 2021

       Domenic Dell'Osso, Jr
       President, Chief Executive Officer and Chief Financial Officer
       CHESAPEAKE ENERGY CORP
       6100 North Western Avenue
       Oklahoma City, Oklahoma 73118

                                                        Re: CHESAPEAKE ENERGY
CORP
                                                            Registration
Statement on Form S-3
                                                            Filed November 5,
2021
                                                            File No. 333-260833

       Dear Mr. Dell'Osso:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

             Please contact Arthur Tornabene-Zalas at 202-551-3162 or Loan
Lauren Nguyen, Legal
       Branch Chief, at 202-551-3642 with any questions.




                 Sincerely,


                 Division of Corporation Finance

                 Office of Energy & Transportation
       cc:                                              Kevin Richardson