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                                                             May 3, 2019

Pablo Manuel Vera Pinto
Chief Financial Officer
Vista Oil & Gas, S.A.B. de C.V.
Calle Volc n 150, Floor 5
Colonia Lomas de Chapultepec, Alcald a Miguel Hidalgo
Mexico City, 11000
Mexico

       Re: Vista Oil & Gas, S.A.B. de C.V.
           Amendment No. 1 to Draft Registration Statement on Form DRS F-1
           Submitted April 18, 2019
           CIK No. 0001762506

Dear Mr. Vera Pinto:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
February 21, 2019 letter.

Form DRS F-1/A filed April 18, 2019

Prospectus Summary
Our Company, page 1

1.     We reissue comment 2 in part. Please revise the first paragraph of page
1 to clarify, as
       you do on page 3, that the concessions you operate have a lower recovery
factor than
       those across on-shore fields in Argentina and analogous on-shore basins
in the United
       States.
 Pablo Manuel Vera Pinto
Vista Oil & Gas, S.A.B. de C.V.
May 3, 2019
Page 2
Summary Historical Reserves and Operating Data
Reserves Data, page 17

2.       We have read your response to comment 6; however, it appears that you
continue to
         aggregate crude oil/condensate reserves with natural gas liquids
reserves throughout your
         filing and in Exhibit 99.1. Revise the presentation of your reserves
to separately disclose
         the figures for your natural gas liquids reserves or tell us why a
revision is not needed.
         Refer to the disclosure requirements under Item 1202(a)(2) and
1202(a)(4) of Regulation
         S-K and FASB ASC 932-235-50-4.
3.       The identification of the individual product types represented in your
reserves, other than
         natural gas, appears to be inconsistent throughout your filing. For
example, the tabular
         disclosure provided on pages 18 and 81 indicates you have crude oil
and condensate
         reserves, page 162 indicates you have oil reserves, page F-152 and
F-247 indicates you
         have oil, condensate and natural gas liquids reserves and page F-262
indicates you have
         liquids reserves. Modify your disclosure as appropriate to resolve
these apparent
         inconsistencies. Refer to the disclosure requirements under Item
1202(a)(2) and
         1202(a)(4) of Regulation S-K and FASB ASC 932-235-50-4.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Capital Expenditures, page 107

4.       We note the revised disclosure added in response to prior comment 14
and believe that
         more specificity is necessary for an understanding of the timing of
the investment
         commitments on both a short-term and long-term basis. As such, please
expand your
         discussion to quantify the amount of capital investment to be made for
each of the fiscal
         periods that comprise the amount you are required to invest under the
relevant
         concessions. Your disclosures should also address total capital
expenditures budgeted in
         future periods, including amounts in addition to the investment
commitments required
         under concessions and joint operations currently disclosed. Explain
the reasons for any
         material increase or decrease in budgeted future capital expenditures
as compared to
         historical periods.
Our Business
Oil and Natural Gas Reserves, Production, page 162

5.     Modify your disclosure of natural gas reserves provided on page 162 and
natural gas
FirstName LastNamePablo Manuel Verato clarify, if true, that the figures
presented represent an
       production provided on page 165 Pinto
Comapany NameVista Oil & Gas, S.A.B.consumed in operations as fuel and the
volumes of
       aggregation of the volumes of gas de C.V.
May 3,marketable or sales gas.
        2019 Page 2
FirstName LastName
 Pablo Manuel Vera Pinto
FirstName LastNamePablo Manuel Vera Pinto
Vista Oil & Gas, S.A.B. de C.V.
Comapany NameVista Oil & Gas, S.A.B. de C.V.
May 3, 2019
May 3, 2019 Page 3
Page 3
FirstName LastName
6.       If the figures provided on pages 162 and 165 represent an aggregation
of the volumes of
         gas consumed in operations as fuel and the volumes of marketable or
sales gas, expand
         your disclosure to separately quantify the portion of the natural gas
that is consumed in
         operations as fuel.
       For questions regarding comments on engineering matters, you may contact
John
Hodgin, Petroleum Engineer, at (202) 551-3699. You may contact Jennifer
O'Brien, Staff
Accountant, at (202) 551-3721 or Shannon Buskirk, Staff Accountant, at (202)
551-3717 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Parhaum J. Hamidi, Attorney-Adviser, at (202) 551-3421 or, in his
absence, Timothy S.
Levenberg, Special Counsel, at (202) 551-3707 with any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Natural
Resources
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