April 18, 2019

Michael Beyer
Chief Financial Officer
Laredo Petroleum, Inc.
15 W. Sixth Street, Suite 900
Tulsa, Oklahoma 74119

       Re: Laredo Petroleum, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed February 14, 2019
           File No. 001-35380

Dear Mr. Beyer:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In some of our comments, we may ask
you to
provide us with information so we may better understand your disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2018

Business
Overview, page 8

1.    We note your disclosure stating that you have identified just one
operating segment:
      exploration and production, subsequent to the sale of your interest in
Medallion Gathering
      & Processing LLC during the fourth quarter of 2017. You previously
associated that
      interest with your Midstream and marketing segment, although the equity
method
      accounting result was not included within the measure of profit or loss
for that segment.
      You had identified Midstream and marketing, along with Exploration and
production of
      oil and natural gas properties, as your "two principal business
segments."

      Given that you continue to engage in the activities that had constituted
your Midstream
      and marketing segment, noting the revenues and costs related to midstream
services and
      your sales and purchases of oil, tell us how you concluded that your
exploration and
 Michael Beyer
Laredo Petroleum, Inc.
April 18, 2019
Page 2
         production activities, along with your midstream and marketing
activities, now represent a
         single operating segment, as defined in FASB ASC 280-10-50-1.

         Please identify the factors and basis of organization used to identify
your reportable
         segment and describe the change in such factors and basis of
organization underlying the
         transition in your segment reporting to comply with FASB ASC
280-10-50-21.
       In closing, 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.

       You may contact Jenifer Gallagher, Staff Accountant at (202) 551-3706 or
Kimberly
Calder, Assistant Chief Accountant at (202) 551-3701 with any questions.



FirstName LastNameMichael Beyer                              Sincerely,
Comapany NameLaredo Petroleum, Inc.
                                                             Division of
Corporation Finance
April 18, 2019 Page 2                                        Office of Natural
Resources
FirstName LastName