UNITED STATES
                                  SECURITIES AND EXCHANGE COMMISSION
                                               WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                                June 6, 2019

  Via E-Mail

  Kai E. Liekefett
  Sidley Austin LLP
  787 Seventh Avenue
  New York, New York 10019

          Re:     Texas Pacific Land Trust Inc.
                  DEFA14A filed May 22, 2019
                  DEFA14A filed May 23, 2019
                  Response Letter dated June 5, 2019
                  File No. 1-00737

  Dear Mr. Liekefett:

          We are in receipt of your letter dated June 5, 2019 responding to our
prior comment letter
  dated May 31, 2019. We continue to have questions concerning your belief that
the Trust may
  use proxies solicited for a meeting originally scheduled for May 22, 2019,
when that meeting has
  now been indefinitely postponed by the Trust. We also have serious concerns
regarding the
  Trust's plan as expressed in your June 5, 2019 letter, to wait until
resolution of its lawsuit against
  Mr. Oliver and his affiliates to inform Trust shareholders of the status of
the proxies it previously
  solicited. Please address the following additional comments in a response
letter, with a view to
  further disclosure to shareholders:

      1. Your June 5, 2019 did not provide the requested legal analysis
regarding your ability to
         use the previously-solicited proxies for what appears to be a new
meeting. According to
         the Trust's filings, the meeting has been postponed indefinitely and
no new meeting date
         has been set. Rule 14a-4 limits a party's ability to use proxies
solicited. Please provide
         your legal analysis of your authority to use proxies solicited for a
specific meeting, when
         that meeting has been postponed (not adjourned) indefinitely, pending
resolution of a
         lawsuit brought by the Trust, which may take years.

      2. The record date for the May 22, 2019 meeting date (which was to be
adjourned until June
         6, 2019) was March 28, 2019. Please describe the applicable provisions
of the Trust's
         governing instruments and applicable state law (if relevant) regarding
how the record
         date is set and how long it remains valid for a meeting which has now
been postponed
         indefinitely. What is the maximum period of time that may elapse
between the record
         date and the date of a shareholders meeting, under the Trust's
governing instruments and
         state law? If the Trust may be required to set a new record date for
the meeting to elect a
         new trustee when it is ultimately held, how does this impact your
analysis of whether
 Kai Liekefett, Esq.
Sidley Austin LLP
June 6, 2019
Page 2


       previously-solicited proxies may be used by the Trust under the proxy
rules or other
       applicable provisions?

       Please respond to the above comments promptly. Direct any questions to
me at
(202) 551-3263.

                                                           Sincerely,

                                                           /s/ Christina Chalk

                                                           Christina Chalk
                                                           Senior Special
Counsel
                                                           Office of Mergers
and Acquisitions