October 29,
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/A filed by Parker Drilling Company
               Filed October 21, 2019
               File No. 005-37314

               Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A
               Filed October 21, 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 14A

General

1.     Please disclose in the filing your responses to prior comments 7, 8, 14,
and 15.

2.     The disclosure indicates parenthetically that the Finance and Strategic
Planning
       Committee recommended the Transaction "by a unanimous vote of directors
present."
       Please disclose which directors were not present for such vote.
 Daniel Fisher, Esq.
October 29, 2019
Page 2



Summary Term Sheet, page 3

3.     We note the references in this section and elsewhere in the filing to
information available
       to the Company as of September 24. Please provide updated information as
close to the
       amended filing date as reasonably practicable.

4.     We note the references on page 12 and elsewhere in the filing to the
"total cash
       requirement" of the Stock Splits. Please revise the disclosure so that
it is clear which
       figures include costs and fees and which do not.

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