SecProbe.io

Mail Stop 4628
May 20 , 201 6

Via E -mail
Christian A. Garcia
Acting 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, 201 5
Filed February 5, 201 6
File No. 1-03492

Dear Mr. Garcia :

We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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 Fiscal Year Ended December 31, 2015

Business, page 1

1. Explain to us how you  have considered the requirement to d isclose the dollar amount of
backlog orders believed to be firm.  See Item 101(C)(1)(viii) of Regulation S -K.

Management's Discussion and Analysis of Financial Condition and Results of Operations, page
21

Results of Operations in 2015 Compared to 2014, page 29

2. In various places in your MD&A, you attribute the change in reported amounts to
multiple factors without indicating the amount contributed by each factor.  For example,
in describing the reduction in completion  and production revenue, you indicate that

Christian A. Garcia
Halliburton Company
May 20 , 201 6
Page 2

 revenue in North America declined “mainly in the United States land market, as a result
of steep rig count declines, pricing concessions, and reduced stimulation activity”. Revise
the analysis of your operating re sults to quantify the effect of each factor identified as the
cause of a material change to the amounts presented as part of your financial statements.
Refer to Item 303(a)(3) of Regulation S -K and FRC 501.04

Critical Accounting Estimates, page 37

Value  of long -lived assets, including intangible assets and goodwill, page 38

3. We note your disclosure regarding the possible impact of the crude oil market on your
goodwill impairment testing.  Tell us whether you had any reporting unit that had a fair
value t hat was not substantially in excess of its carrying value as of the date of your most
recent impairment test.  If so, explain to us how you considered providing the following
disclosure:

 The percentage by which fair value exceeded carrying value as of th e date of the most
recent test;

 The amount of goodwill allocated to the reporting unit;

 A description of the methods and key assumptions used and how the key assumptions
were determined;

 A discussion of the degree of uncertainty associated with the k ey assumptions. The
discussion regarding uncertainty should provide specifics to the extent possible (e.g., the
valuation model assumes recovery from a business downturn within a defined period of
time); and,

 A description of potential events and/or chan ges in circumstances that could reasonably
be expected to negatively affect the key assumptions.

See Item 303(a)(3)(ii) of Regulation S -K, which  requires  a description  of a known
uncertainty, and Section  V of SEC Release 33-8350, which  states  that under existing
MD&A disclosure  requirements,  you should address  material  implications of
uncertainties  associated  with the methods,  assumptions  and estimates  underlying your
critical  accounting  measurements.

Note that similar considerations apply to disclosure regarding estimates associated with
other long -lived assets, including intangible assets other than goodwill.

Christian A. Garcia
Halliburton Company
May 20 , 201 6
Page 3

 Notes to Consolidated Financial Statements, page 50

Note 3. Impairments and Other Charges, page 54

4. Expand your disclosure regarding impairm ents of assets classified as held and used to
indicate the method or methods used to determine fair value. See FASB ASC paragraph
360-10-50-2(c).

Note 4. Business Segment and Geographic Information, page 56

5. Disclosure under this note and in the Business  section of your filing indicates that you
generate revenue from a variety of different products and services, while disclosure in
your MD&A indicates that changes in the amount of revenue from these various products
and services have had differing impacts  on your results of operations.  In view of these
factors, explain to us how you have considered the disclosure requirement under FASB
ASC 280 -10-50-40 regarding revenues from external customers for each product and
service or each group of similar product s and services.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes 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 provide  a written st atement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

Christian A. Garcia
Halliburton Company
May 20 , 201 6
Page 4

 You may contact Wei Lu, Staff Accountant, at (202)  551-3725 if you have questions
regarding comments on the financial statements and related matters.  Please contact me at (202)
551-3489 with any other questions.

Sincerely,

 /s/ Brad Skinner

Brad Skinner
Senior Assistant Chief Accountant
Office of Natural Resources