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United States securities and exchange commission logo





                            September 28, 2020

       Anne Liversedge
       Corporate Secretary
       Teekay LNG Partners L.P.
       4th Floor, Belvedere Building
       69 Pitts Bay Road
       Hamilton, HM 08
       Bermuda

                                                        Re: Teekay LNG Partners
L.P.
                                                            Form 20-F for the
Year Ended December 31, 2019
                                                            Filed April 9, 2020
                                                            Form 6-K Filed
August 13, 2020
                                                            File No. 001-32479

       Dear Ms. Liversedge:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following 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 these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 6-K Filed August 13, 2020

       Definitions and Non-GAAP Financial Measures, page 6

   1.                                                   You present the
non-GAAP measure Adjusted Revenues which includes revenues from
                                                        your proportionate
economic ownership of each vessel owned by your equity-accounted
                                                        joint ventures. Please
tell us whether you have any legal claims to the revenues of your
                                                        equity-accounted joint
ventures, why this presentation is not an individually tailored
                                                        accounting principle
and why you believe your presentation in in compliance with 100(b)
                                                        of Regulation G. Please
refer to Question 100.04 of the Non-GAAP C&DI.
 Anne Liversedge
FirstName LastNameAnne
Teekay LNG  Partners L.P. Liversedge
Comapany 28,
September NameTeekay
              2020      LNG Partners L.P.
September
Page 2    28, 2020 Page 2
FirstName LastName
Form 20-F for the Year Ended December 31, 2019

Selected Financial Data
Non-GAAP Measures, page 5

2.       We note that voyage expenses include all expense unique to a
particular voyage, including
         fuel expenses, port fees, cargo loading and unloading expenses, canal
tolls, agency fees
         and commissions. We also note that you pay for voyage expenses for
voyage charters and
         that the customer pays voyage expenses under time charters. Tell us
whether voyage
         expenses for your voyage charters are passed through to your customers
at cost or marked
         up. If passed through at cost, confirm to us that the same amount
recognized as voyage
         expense is recognized within revenues as reimbursement for such costs.
3.       We note your presentation of the non-GAAP measure net voyage revenues.
Given that
         this measure reduces your reported revenue by a non-revenue line item,
explain to us your
         basis for presenting this as a measure of revenue. If net voyage
revenues is intended to be
         presented as a measure of gross profit, tell us whether and, if so,
how, you considered the
         use of a different caption and the presentation of a reconciliation
for this non-GAAP
         measure to the most directly comparable GAAP measures, i.e. gross
margin that includes
         depreciation, depletion and amortization. See Item 10(e)(1)(i)(B) of
Regulation S-K.
         Alternatively, if net voyage revenues is intended to be a measure of
gross profit, explain to
         us how you considered presenting the reimbursement of voyage expenses
as a separate
         revenue item on the face of your consolidated statements of income.
4.       We note your adjustment for direct finance and sale-type lease
payments received in
         excess of revenue recognized within your adjusted EBITDA
reconciliation. Please
         describe how this adjustment is calculated and why you believe this is
not an individually
         tailored accounting principle, Please refer to Question 100.04 of the
Non-GAAP CD&I.


       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 Yong Kim, Staff Accountant at 202-551-3323 or Gus
Rodriguez,
Accounting Branch Chief, at 202-551-3752 with any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Energy
& Transportation
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