SecProbe.io

July 20, 2011
 Via Facsimile

Mr. Mark A. McCollum Chief Financial Officer Halliburton Company 3000 North Sam Houston Parkway East Houston, Texas 77032
Re: Halliburton Company
  Form 10-K for Fiscal Year Ended December 31, 2010
Filed February 17, 2011
  File No. 001-03492

Dear Mr. McCollum:
 We have reviewed your filing 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for Fiscal Year Ended December 31, 2010

 General

 1. You discuss in your filing that your comple tion and production services include hydraulic
fracturing and acidizing se rvices. Please tell us, with  a view for disclosure:
• what percentage of your services  involves hydraulic fracturing;
• your anticipated costs and funding associat ed with hydraulic fracturing services;
and
• whether there have been any incidents, ci tations, or suits related to your hydraulic
fracturing operations for environmental concerns, and if so, what your response
has been.

2. In regard to your hydraulic fracturing serv ices and more generally the services you
provide in your completion and production segm ent, please also tell us what steps you

Mark A. McCollum  Halliburton Company July 20, 2011 Page 2

 have taken to minimize any potential environm ental impact.  As part of your response,
please explain your role as compared to that  of the well operator.  For example, and
without limitation, please explain if you:
• have steps or technology in place to en sure that the services you provide for
drilling, casing, cementing, and well completi ons adhere to known best practices;
• have systems in place to monitor the rate  and pressure of the fracturing treatment
in real time for any abrupt change in ra te or pressure and/or  detection of fluid
leak-off;
• evaluate the environmental impact of additives to your fr ack fluid, including
disclosure of all chemicals involved, in the volume/concentration and total amounts utilized; and
• minimize the use of water and/or dispose of  it in a way that minimizes the impact
to nearby surface water.

3. In light of the public concern over the risks relating to hydrau lic fracturing, please review
your disclosure in your filing and periodic repor ts to ensure that you have disclosed all
material information regarding your potential liability as a se rvice provider.  This would
include, for example, your potential liability  in connection with any environmental
contamination related to your fracturing opera tions.  For example, and without limitation,
please consider, and address in your res ponse, the following with respect to your
hydraulic fracturing services and operations:
• the applicable policy limits and deductib les related to your insurance coverage;
• your related indemnification obligations  and those of your customers, if
applicable;
• your insurance coverage with respect to any liability related to any resulting
negative environmental effects; and
• the risks for which you are insured fo r your hydraulic fracturing operations.

Financial Instrument Market Risk, page 57

4. Please expand your disclosures in future fili ngs to provide the information required by
and discussed in Item 305 of Regulation S-K.  It is unclear how your current disclosures
meet one of the three disclosure alternativ es described in Item 305(a).  Additionally,
please expand your disclosures to qualitat ively discuss how you manage each of the
primary market risks you are currently exposed  to.  Please note Gene ral Instruction 6 of
Regulation S-K, Item 305 as to the location of  your disclosures outside of the financial
statements.  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Mark A. McCollum  Halliburton Company July 20, 2011 Page 3

  In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Suying Li at (202) 551-3335 or Shannon Bu skirk at (202) 551-3717 if
you have questions regarding comments on the fina ncial statements and related matters.  Please
contact Kevin Dougherty at (202) 551-3271 or me  at (202) 551-3745 with  any other questions.

Sincerely,
   /s/H. Roger Schwall
H. Roger Schwall Assistant Director