October
7, 2019

Daniel Fisher, Esq.
Akin Gump Strauss Hauer Feld LLP
One Bryant Park
Bank of America Tower
New York, NY 10036

       Re:    Parker Drilling Company
              Schedule 13E-3 filed by Parker Drilling Company
              Filed September 11, 2019
              File No. 005-37314

              Preliminary Proxy Statement on Schedule 14A
              Filed September 11, 2019
              File No. 001-07573

Dear Mr. Fisher:

       We have reviewed the filings referenced above and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand the disclosure.

       Please respond to this letter by amending the filings, by providing the
requested
information, or by advising us when you will provide the requested response. If
you do not
believe our comments apply to the facts and circumstances or do not believe an
amendment is
appropriate, please tell us why in your response.

       After reviewing any amendment to the filings and the information you
provide in
response to these comments, we may have additional comments. Please note that
capitalized
terms used but not defined herein have the meanings ascribed to them in the
filings.

Schedule 13E-3

1.     Please refile Exhibits (c)(i) through (c)(iv) in a manner that ensures
that all slides
       contained in such presentations are clearly legible.

Preliminary Proxy Statement on Schedule 14A

General

2.     Please revise to mark both the proxy statement and attached form of
proxy as a
       "Preliminary Copy," as required by Rule 14a-6(e)(1) of Regulation 14A.
 Daniel Fisher, Esq.
October 7, 2019
Page 2



Vote Required for Approval of the Stock Splits and the Adjournment Proposal at
the Special
Meeting, page 9

3.     Please state clearly in this section and elsewhere that, assuming V rde
and Brigade vote
       as indicated, the vote required for approval is assured.

4.     Please explain why the adjournment proposal is necessary, and why the
disclosure
       repeatedly emphasizes such proposal, in light of the apparently
"locked-up" nature of the
       proposal.

Treatment of Beneficial Holders (Stockholders Holding Shares in "Street Name"),
page 9

5.     We note the disclosure here and related disclosure on pages 13-14 and
elsewhere. Please
       ensure that such disclosure is consistent with the examples given on
pages 31-32.

Why is the Company proposing to carry out a Forward Stock Split following the
Reverse Stock
Split?, page 13

6.     Please advise us as to whether the more straightforward treatment of
outstanding warrants
       and options was also a factor in deciding to propose a Forward Stock
Split.

Background of the Stock Splits to Effect the Transaction, page 22

7.     Please briefly describe V rde's and Brigade's involvement in the Chapter
11 Cases and
       their related influence on the board of directors.

8.     Please identify the members of the Finance and Strategic Planning
Committee and how
       they were chosen.

9.     Please disclose to what extent V rde and Brigade were involved in the
series of events
       that led to the Board's approval of the Stock Splits and the overall
Transaction.

10.    We note the repeated use of the phrase "advantages and considerations"
in this section.
       Please advise us as to why such phrase, rather than "advantages and
disadvantages," is
       used.

11.    Please explain the origin of the proposed amount of $30 for the Cash
Payment.

Reservation of Rights, page 32

12.    We note the following disclosure here and on page 6: "The Board has
reserved the right
       to abandon the Stock Splits and the overall Transaction at any time if
it believes that the
       Stock Splits or the Transaction are no longer in the best interests of
our stockholders,
       whether prior to or following the Special Meeting." Please disclose
whether there are
 Daniel Fisher, Esq.
October 7, 2019
Page 3


       any legal constraints on the Board's ability to abandon the Transaction.
In the event that
       the Special Meeting is held and shareholder approval is obtained, please
describe under
       what circumstances the Board would decide not to move forward with the
Stock Splits.
       Please disclose, in reasonable detail, the anticipated timeline for
effecting the Stock Splits
       following the Special Meeting and the factors that might affect such
timeline.

Fairness of the Stock Splits to effect the Transaction, page 33

13.    We note the disclosure on page 34 that generally indicates an absence of
firm offers
       involving the Company by unaffiliated persons. Please disclose whether
any affiliate has
       made any such offer since the Company's emergence from bankruptcy.

Fairness Opinion of Financial Advisor, page 36

14.    Please explain the basis for Houlihan Lokey's application of the 3.25x
to 4.25x, 3.00x to
       4.00x, and 2.25x to 3.00x multiple ranges in the Selected Companies
Analysis, as well as
       the 2.25x to 2.75x multiple range used in the two Discounted Cash Flow
analyses.

15.    Please explain the basis for the 12.50% to 13.50% and 11.75% to 12.75%
discount ranges
       used in the first and second Discounted Cash Flow analyses,
respectively.

Please contact me at (202) 551-8094 if you have any questions regarding our
comments.

                                                             Sincerely,

                                                             /s/ David M.
Plattner

                                                             David M. Plattner
                                                             Special Counsel
                                                             Office of Mergers
and Acquisitions