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United States securities and exchange commission logo





                             September 21, 2020

       Francesco Gattei
       Chief Financial Officer
       ENI SPA
       Piazza Vanoni, 1
       20097 San Donato Milanese (Italy)

                                                        Re: ENI SPA
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2019
                                                            Filed April 2, 2020
                                                            File No. 001-14090

       Dear Mr. Gattei:

              We have reviewed your filing 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 20-F for the Fiscal Year Ended December 31, 2019

       Business Overview
       Exploration & Production
       Oil and Gas Properties, Operations and Acreage, page 45

   1.                                                   Expand your disclosure
to provide the expiration dates of material concentrations of your
                                                        undeveloped acreage by
geographic area as of December 31, 2019. Refer to the
                                                        disclosure requirements
in Item 1208(b) of Regulation S-K.
       Supplemental Oil and Gas Information (Unaudited)
       Oil and Natural Gas Reserves, page F-152

   2.                                                   Expand your disclosure
to clarify the extent to which the reserves and production figures
                                                        presented under this
section include natural gas and/or crude oil and condensate volumes
                                                        consumed in operations
to comply with FASB ASC 932-235-50-10.
 Francesco Gattei
ENI SPA
September 21, 2020
Page 2
3.       Your explanation of the changes in total proved reserves provided on
pages 38 and 39
         identifies multiple factors impacting your proved reserves as well as
both positive and
         negative changes summed into a single quantity without indicating the
specific amount
         attributable to each factor. For example, the discussion on page 38
discloses the net
         change resulting from the combination of purchases and sales of proved
reserves.

         Expand your disclosure to address the overall change in the line item
by identifying the
         specific amount attributable to each factor that resulted in changes
in the total net
         quantities of your proved reserves. Any figures that are net of both
positive and negative
         factors should be separately identified and quantified such that the
changes in each line
         item are fully explained.

         In particular, disclosure relating to revisions in previous estimates
should identify the
         individual underlying factors such as the changes caused by commodity
prices, well
         performance, uneconomic proved undeveloped locations or changes
resulting from the
         removal of proved undeveloped locations due to changes in a previously
adopted
         development plan.

         This comment applies to the disclosure of significant changes in total
proved reserves for
         each line item shown in the reserves reconciliation, other than
production, and for each of
         the periods presented, e.g. the periods ending December 31, 2019, 2018
and 2017,
         respectively, and to the disclosure of material changes that occurred
in proved
         undeveloped reserves during the current fiscal year provided on page
40. Refer to FASB
         ASC 932-235-50-5, Item 302(b) of Regulation S-K, and Item 1203(b) of
Regulation S-K,
         respectively.
        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 Sandra Wall, Petroleum Engineer, at 202-551-4727 if you
have
questions regarding the engineering comments. Please contact Craig Arakawa,
Branch Chief, at
202-551-3650 with any other questions.



FirstName LastNameFrancesco Gattei                             Sincerely,
Comapany NameENI SPA
                                                               Division of
Corporation Finance
September 21, 2020 Page 2                                      Office of Energy
& Transportation
FirstName LastName
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