WEATHERFORD INTERNATIONAL LTD.
2000 St. James Place
Houston, Texas 77056
VIA EDGAR
December 9, 2019
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Timothy Levenberg
Re: |
| Weatherford International Ltd. and Co-Applicants |
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| Form T-3 (File No. 022-29075) |
Ladies and Gentlemen:
We refer to the Application for Qualification of Indenture on Form T-3 (File No. 022-29075) (as amended, the “Form T-3”) of Weatherford International Ltd. (the “Company”), initially filed on June 28, 2019 with the Securities and Exchange Commission (the “Commission”), in connection with the qualification under the Trust Indenture Act of 1939, as amended (the “Act”), of the indenture governing the Company’s new 11.00% Senior Unsecured Notes due 2024.
On November 27, 2019, the Company filed Amendment No. 4 to the above referenced Form T-3. In accordance with Section 307(c) of the Act, we hereby respectfully request the acceleration of the effectiveness of the above referenced Form T-3 so that it may become effective at or prior to 5:00 p.m. (Eastern time) on December 11, 2019 or as soon as reasonably practicable thereafter.
In connection with the filing of the Form T-3, the Company hereby acknowledges that:
· should the Commission or the Staff of the Division of Corporation Finance of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
· the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
· the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact John M. Greer of Latham & Watkins LLP at (713) 546-7472 to confirm the effectiveness of the Form T-3.
[Signature Page Follows]
| WEATHERFORD INTERNATIONAL LTD. | ||
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| By: | /s/ Mohammed Dadhiwala | |
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| Name: | Mohammed Dadhiwala |
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| Title: | Vice President |
| WEATHERFORD INTERNATIONAL, LLC | ||
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| By: | /s/ Christine M. Morrison | |
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| Name: | Christine M. Morrison |
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| Title: | Sole Manager of Sole Member |
| WEATHERFORD INTERNATIONAL PLC | ||
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| By: | /s/ Stuart Fraser | |
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| Name: | Stuart Fraser |
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| Title: | Chief Financial Officer |
| ADVANTAGE R&D, INC. |
| BENMORE IN-DEPTH CORP. |
| CASE SERVICES, INC. |
| COLOMBIA PETROLEUM SERVICES CORP. |
| COLUMBIA OILFIELD SUPPLY, INC. |
| DATALOG ACQUISITION, LLC |
| DISCOVERY LOGGING, INC. |
| EDINBURGH PETROLEUM SERVICES AMERICAS INCORPORATED |
| EPRODUCTION SOLUTIONS, LLC |
| HIGH PRESSURE INTEGRITY, INC. |
| IN-DEPTH SYSTEMS, INC. |
| INTERNATIONAL LOGGING LLC |
| INTERNATIONAL LOGGING S.A., LLC |
| PD HOLDINGS (USA), L.P. |
| PRECISION DRILLING GP, LLC |
| PRECISION ENERGY SERVICES, INC. |
| PRECISION OILFIELD SERVICES, LLP |
| STEALTH OIL & GAS, INC. |
| TOOKE ROCKIES, INC. |
| VISEAN INFORMATION SERVICES INC. |
| VISUAL SYSTEMS, INC. |
| WARRIOR WELL SERVICES, INC. |
| WEATHERFORD (PTWI), L.L.C. |
| WEATHERFORD ARTIFICIAL LIFT SYSTEMS, LLC |
| WEATHERFORD DISC INC. |
| WEATHERFORD GLOBAL SERVICES LLC |
| WEATHERFORD INVESTMENT INC. |
| WEATHERFORD LATIN AMERICA LLC |
| WEATHERFORD MANAGEMENT, LLC |
| WEATHERFORD TECHNOLOGY HOLDINGS, LLC |
| WEATHERFORD U.S., L.P. |
| WEATHERFORD URS HOLDINGS, LLC |
| WEATHERFORD/LAMB, INC. |
[Signature Page to Acceleration Request]
| WEUS HOLDING, LLC | ||
| WIHBV LLC | ||
| WUS HOLDING, L.L.C. | ||
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| By: | /s/ Christine M. Morrison | |
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| Name: | Christine M. Morrison |
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| Title: | Vice President |
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| SABRE DRILLING LTD. | ||
| WEATHERFORD BERMUDA HOLDINGS LTD. | ||
| WEATHERFORD COLOMBIA LIMITED | ||
| WEATHERFORD DRILLING INTERNATIONAL HOLDINGS (BVI) LTD. | ||
| WEATHERFORD HOLDINGS (BERMUDA) LTD. | ||
| WEATHERFORD INTERNATIONAL HOLDING (BERMUDA) LTD. | ||
| WEATHERFORD PANGAEA HOLDINGS LTD. | ||
| WEATHERFORD SERVICES, LTD. | ||
| WOFS ASSURANCE LIMITED | ||
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| By: | /s/ Mohammed Dadhiwala | |
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| Name: | Mohammed Dadhiwala |
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| Title: | Vice President |
| WEATHERFORD HOLDINGS (BVI) LTD. | ||
| WEATHERFORD OIL TOOL MIDDLE EAST LIMITED | ||
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| By: | /s/ Mohammed Dadhiwala | |
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| Name: | Mohammed Dadhiwala |
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| Title: | Senior Vice President |
| KEY INTERNATIONAL DRILLING COMPANY LIMITED | ||
| WEATHERFORD DRILLING INTERNATIONAL (BVI) LTD. | ||
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| By: | /s/ Andrew David Gold | |
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| Name: | Andrew David Gold |
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| Title: | President |
| PRECISION ENERGY INTERNATIONAL LTD. | ||
| PRECISION ENERGY SERVICES COLOMBIA LTD. | ||
| PRECISION ENERGY SERVICES ULC | ||
| WEATHERFORD (NOVA SCOTIA) ULC | ||
| WEATHERFORD CANADA LTD. | ||
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| By: | /s/ Raymond Charles Smith | |
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| Name: | Raymond Charles Smith |
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| Title: | Vice President |
| WEATHERFORD HOLDINGS (SWITZERLAND) GMBH | ||
| WEATHERFORD MANAGEMENT COMPANY SWITZERLAND SÀRL | ||
| WEATHERFORD WORLDWIDE HOLDINGS GMBH | ||
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| By: | /s/ Valentin Mueller | |
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| Name: | Valentin Mueller |
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| Title: | Managing Officer |
[Signature Page to Acceleration Request]
| WEATHERFORD PRODUCTS GMBH | ||
| WEATHERFORD SWITZERLAND TRADING AND DEVELOPMENT GMBH | ||
| WOFS INTERNATIONAL FINANCE GMBH | ||
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| By: | /s/ Mathias Neuenschwander | |
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| Name: | Mathias Neuenschwander |
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| Title: | Managing Officer |
| WEATHERFORD SERVICES S. DE R.L. | ||
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| By: | /s/ Mathias Neuenschwander | |
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| Name: | Mathias Neuenschwander |
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| Title: | Managing Officer, |
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| Weatherford Worldwide Holdings GmbH, as shareholder |
| WEATHERFORD EUROPEAN HOLDINGS (LUXEMBOURG) S.À R.L. | ||
| WEATHERFORD INTERNATIONAL (LUXEMBOURG) HOLDINGS S.À R.L. | ||
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| By: | /s/ Mathias Neuenschwander | |
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| Name: | Mathias Neuenschwander |
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| Title: | Manager A |
| WOFS SWISS FINANCE GMBH | ||
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| By: | /s/ Arjana Cabariu-Truong | |
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| Name: | Arjana Cabariu-Truong |
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| Title: | Managing Officer |
| WEATHERFORD EURASIA LIMITED | ||
| WEATHERFORD IRISH HOLDINGS LIMITED | ||
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| By: | /s/ Neil Alexander MacLeod | |
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| Name: | Neil Alexander MacLeod |
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| Title: | Director |
| WEATHERFORD U.K. LIMITED | ||
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| By: | /s/ Alexander Olsson | |
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| Name: | Alexander Olsson |
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| Title: | Director |
| WEATHERFORD NETHERLANDS B.V. | ||
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| By: | /s/ August Willem Versteeg | |
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| Name: | August Willem Versteeg |
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| Title: | Managing Director |
[Signature Page to Acceleration Request]
| WEATHERFORD NORGE AS | ||
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| By: | /s/ Geir Egil Moller Olsen | |
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| Name: | Geir Egil Moller Olsen |
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| Title: | Chairman of the Board |
| WEATHERFORD AUSTRALIA PTY LIMITED | ||
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| By: | /s/ Robert Antonio DeGasperis | |
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| Name: | Robert Antonio DeGasperis |
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| Title: | Director |
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| WEATHERFORD OIL TOOL GMBH | ||
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| By: | /s/ Marco Seffer | |
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| Name: | Marco Seffer |
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| Title: | Managing Director |
[Signature Page to Acceleration Request]
