SecProbe.io

November 16, 2011
 Via E-mail

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. 1-03492

Dear Mr. McCollum:
 We have reviewed your response letter filed August 2, 2011 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

 Risk Factors, page 6

 1. We note your responses to comments 2 and 3 fr om our letter dated July 20, 2011 as well
as your risk factor discussi on at page 7 under “Certain ma tters relating to the Macondo
well… and similar catastrophic events…” and page 15 under “The adoption of any future
federal or state laws or  implementing regulations  imposing reporting obligations on…the
hydraulic fracturing process….”   In light of the information you have provided in
response to comment 2 regarding your proced ures and historical experience with your
hydraulic fracturing operations and comment 3 regarding your potentia l liability, please
confirm that you believe your current risk fact or disclosure addresses all your material
risks and that there are no material operat ional and financial risks stemming from your
fracking operations that requi re disclosure hereunder.

Mark A. McCollum  Halliburton Company November 16, 2011 Page 2

 2. If you believe that there are no specific mate rial operational and fi nancial risks stemming
from your hydraulic fracturing operations, pl ease consider disclosing the information
from prior comments 2 and 3 to provide contex t for the absence of any such risk factor
disclosure addressing the ope rational and financial risks stemming from your hydraulic
fracturing operations , and to better explain you r role in the hydrauli c fracturing process.
In this regard, we note that at present, your business discussion only lists in a summary
fashion the services you provi de under your two segments.
 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.
 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
cc: Via E-mail

 Eric C. Swanson  Baker Botts L.L.P.