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United States securities and exchange commission logo





                             November 3, 2021

       Eduardo Maranhao
       Principal Financial Officer
       GOLAR LNG LTD
       2nd Floor, S.E. Pearman Building
       9 Par-la-Ville Road, Hamilton
       HM 11 Bermuda

                                                        Re: GOLAR LNG LTD
                                                            Form 20-F for the
Fiscal Year ended December 31, 2020
                                                            Filed April 22,
2021
                                                            Response Letter
dated September 17, 2021
                                                            File No. 000-50113

       Dear Mr. Maranhao:

              We have reviewed your September 17, 2021 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       September 3, 2021 letter.

       Form 20-F for the Fiscal Year ended December 31, 2020

       Operating and Financial Review and Prospects
       Operating Results, page 60

   1.                                                   We note that you have
proposed disclosure revisions in response to prior comment one
                                                        that include
reconciliations between consolidated net loss and Adjusted EBITDA,
                                                        although your proposed
revisions utilize both GAAP and non-GAAP labels for the same
                                                        segment performance
measures; remove the Adjusted EBITDA totals from your
                                                        tabulation of segment
results without explanation, and do not include a discussion of the
                                                        reconciling items or
consolidated results of operations.
 Eduardo Maranhao
GOLAR LNG LTD
November 3, 2021
Page 2
         Please further expand your disclosures to address the economic
activity that is reflected in
         the consolidated measure of net profit/(loss), particularly where such
activity is not
         covered by the discussion of segment activity. This should be provided
for the
         consolidated entity, in advance of your discussion of operating
results for the segments.
         The totals in the segment tabulations may be retained to correspond
with your disclosures
         on page F-34, and you may reposition the table of Other Operating
Results on page 64 to
         accompany and facilitate your discussion of the consolidated results
of operations.

         The non-GAAP reconciliations proposed in Appendix 1 should be further
revised to either
         eliminate the measures of profit/(loss) by segment, since this is a
GAAP label and the
         allocations necessary to compute the corresponding GAAP measures have
not been made
         to the segments (i.e. in which case, the reconciliations should be
retained for the
         consolidated measures only), or to include the allocations necessary
to yield GAAP
         measures of profit/(loss) for the reportable operating segments.
Financial Statements
Note 6 - Segment Information, page F-33

2.       We note that you have proposed disclosure revisions in response to
prior comment three
         that include reconciliations of the segment performance measures to
consolidated profit or
         loss before income taxes, although your proposed revisions utilize
both GAAP and non-
         GAAP labels for the same segment performance measures.

         The segment disclosures proposed in Appendix 2 should be further
revised to either
         eliminate the measures of profit/(loss) by segment since this is a
GAAP label and the
         allocations necessary to compute the corresponding GAAP measures have
not been made
         to the segments (i.e. the reconciliations would be limited to the
consolidated measures of
         Adjusted EBITDA, as cross tabulated from the segment details), or to
include the
         allocations necessary to yield GAAP measures of profit/(loss) for the
segments.
        You may contact Mark Wojciechowski, Staff Accountant, at (202) 551-3759
or Karl
Hiller, Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the
financial statements and related matters.



FirstName LastNameEduardo Maranhao                             Sincerely,
Comapany NameGOLAR LNG LTD
                                                               Division of
Corporation Finance
November 3, 2021 Page 2                                        Office of Energy
& Transportation
FirstName LastName
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