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                             September 22, 2022

       Jack Hightower
       Chief Executive Officer
       HighPeak Energy, Inc.
       421 W. 3rd Street, Suite 1000
       Fort Worth, TX 76102

                                                        Re: HighPeak Energy,
Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed September 7,
2022
                                                            File No. 333-267311

       Dear Mr. Hightower:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comments. 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 letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-3 filed September 7, 2022

       General

   1.                                                   Please confirm your
understanding that we will not be in a position to accelerate the
                                                        effectiveness of your
registration statement until our comments relating to your Form 10-
                                                        K for the fiscal year
ended December 31, 2021 have been resolved.
               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.

              Refer to Rules 460 and 461 regarding requests for acceleration.
Please allow adequate
       time for us to review any amendment prior to the requested effective
date of the registration
       statement.
 Jack Hightower
HighPeak Energy, Inc.
September 22, 2022
Page 2

       You may contact Cheryl Brown, Staff Attorney, at (202) 551-3905 or Kevin
Dougherty,
Staff Attorney, at (202) 551-3271 with any questions.



                                                        Sincerely,
FirstName LastNameJack Hightower
                                                        Division of Corporation
Finance
Comapany NameHighPeak Energy, Inc.
                                                        Office of Energy &
Transportation
September 22, 2022 Page 2
cc:       Sarah Knight Morgan
FirstName LastName