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May 18, 2023
R. Scott Rowe
Chief Executive Officer
Flowserve Corporation
5215 N. O' Connor Blvd., Suite 700
Irving, TX 75039
Re:Flowserve Corporation
Form 10-K for the Fiscal Year ended December 31, 2022
Filed March 7, 2023
File No. 001-13179
Dear R. Scott Rowe:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year ended December 31, 2022
Managements Discussion and Analysis of Financial Condition and Results of Operations
Our Results of Operations, page 31
1.We note that your discussion and analysis includes quantifying changes in various
measures, such as bookings, sales and backlog, that are attributable to changes in foreign
currency exchange rates, and in your associated earnings release filed on Form 8-K, also
presenting various percentages of changes in line items on a constant currency basis.

Please revise your disclosures as necessary to address the following points:

•Any results that are presented on a constant currency basis should be identified as
non-GAAP measures, as defined in Item 10(e)(1) of Regulation S-K.

•The process utilized for calculating the constant currency amounts should be
described sufficiently to understand your characterization of the effects, as would

 FirstName LastNameR. Scott Rowe
 Comapany NameFlowserve Corporation
 May 18, 2023 Page 2
 FirstName LastNameR. Scott Rowe
Flowserve Corporation
May 18, 2023
Page 2
include your references to "negative currency effects" in describing various changes
in your annual report.

•The constant currency percentages should be accompanied by the respective constant
currency dollar amounts, consistent with the guidance in the answer to Question
104.06 of our Compliance and Disclosure Interpretations for Non-GAAP measures.

Please submit the revisions that you propose to address the concerns outlined above as
well as those that are covered by the following comment.
2.We note that non-GAAP disclosures in your earnings release covering the three months
and fiscal years ended December 31, 2022 and 2021, appear to be oriented towards
presenting non-GAAP statements of operations, and have the effect of presenting various
GAAP amounts as non-GAAP measures, and non-GAAP measures without adequate
details of reconciling items. Please revise your disclosures to address the following points.

•Identify the most directly comparable GAAP measure for each non-GAAP measure
that you present along with a statement disclosing the reasons you believe the non-
GAAP financial measures provide useful information to investors regarding your
financial condition and results of operations.

•Include a reconciliation from the most directly comparable GAAP measure to your
non-GAAP measure, having separate lines for each reconciling item quantified and
accompanied by appropriate descriptions to comply with Rule 100(a)(2) of
Regulation G, and Item 10(e)(1)(i)(B) of Regulation S-X.

•The adjustments referenced in footnotes to your tabulations for "reversal of
realignment exit tax," "reversals of expenses that were adjusted for Non-GAAP
measures in previous periods," "realignment related tax release," and "duplicate
interest expense," should be described further to understand the nature of and
rationale for making the adjustment in presenting your non-GAAP measures.

•GAAP measures that are not subject to adjustment should not be presented in a
column for non-GAAP measures and you should adhere to the guidance concerning
prominence in the answers to Questions 102.10(a) and (c) of our Compliance and
Disclosure Interpretations for Non-GAAP measures.

•If non-GAAP measures are presented for successive periods, the format utilized for
reconciliations should be conducive to making comparisons, not only with regard to
the measures, but also of the reconciling items and overall composition.

            In closing, 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.

 FirstName LastNameR. Scott Rowe
 Comapany NameFlowserve Corporation
 May 18, 2023 Page 3
 FirstName LastName
R. Scott Rowe
Flowserve Corporation
May 18, 2023
Page 3
            You may contact Joseph Klinko, Staff Accountant, at (202) 551-3824 or Karl Hiller,
Branch Chief, at (202) 551-3686 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation