United States securities and exchange commission logo February 1, 2022 John 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 24, 2022 File No. 333-262314 Dear Mr. Lindsay: We have limited our review of your registration statement to those issues we have addressed in our 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 this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Registration Statement On Form S-4 Filed on January 24, 2022 General 1. Please be advised that we will not be in a position to accelerate the effectiveness of your registration statement until all comments relating to your Form 10-K for the fiscal year ended December 31, 2021 have been resolved. 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. John Lindsay Helmerich & Payne, Inc. February 1, 2022 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. You may contact Arthur Tornabene-Zalas at (202) 551-3162 or Karina Dorin, Staff Attorney, at (202) 551-3763 with any questions. Sincerely, FirstName LastNameJohn Lindsay Division of Corporation Finance Comapany NameHelmerich & Payne, Inc. Office of Energy & Transportation February 1, 2022 Page 2 cc: Hillary Holmes FirstName LastName