TEXT-EXTRACT 2 filename2.txt February 5, 2019 John W. Lindsay President and Chief Executive Officer Helmerich & Payne, Inc. 1437 South Boulder Avenue, Suite 1400 Tulsa, OK 74119 Re: Helmerich & Payne, Inc. Registration Statement on Form S-4 Filed January 29, 2019 File No. 333-229398 Dear Mr. Lindsay: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Karina Dorin, Attorney Advisor, at (202) 551-3763 with any questions. Sincerely, Division of Corporation Finance Office of Natural Resources