United States securities and exchange commission logo November 18, 2020 Barton Brookman President and Chief Executive Officer PDC ENERGY, INC. 1775 Sherman Street, Suite 3000 Denver, Colorado 80203 Re: PDC ENERGY, INC. Form 10-K for Fiscal Year Ended December 31, 2019 Filed February 27, 2020 File No. 001-37419 Dear Mr. Brookman: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Energy & Transportation