SecProbe.io

October 17, 2024
Eric Carre
Chief Financial Officer
Halliburton Company
3000 North Sam Houston Parkway East
Houston, Texas 77032
Re:Halliburton Company
Form 8-K filed September 3, 2024
File No. 001-03492
Dear Eric Carre:
            We have reviewed your filing and have the following comment.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 8-K filed September 3, 2024
General
We note the reference to the previous Form 8-K, which disclosed under Item 8.01 that
you became aware of the cybersecurity incident on August 21, 2024. Please advise us
why you filed under Item 1.05 and tell us whether or not this incident is a material
cybersecurity incident. The Item 1.05 Form 8-K states your belief that the incident has
not had, and is not reasonably likely to have, a material impact on your financial
condition or results of operations. You then state that you remain subject to various
risks due to the incident, including "the adequacy of processes during the period of
disruption, diversion of management’s attention, potential litigation, changes in
customer behavior, and regulatory scrutiny." Please advise us to what extent you
considered qualitative factors in your materiality analysis and not just potential impact
on financial condition and results of operations. As the Commission noted in the
adopting release, the rule’s inclusion of “financial condition and results of operations”
is not exclusive; companies should consider qualitative factors alongside quantitative
factors in assessing the material impact of an incident. For example, consider impacts
on customer relationships, competitiveness, and potential reputational harm related to
the cybersecurity incident. Please tell us what were the qualitative or quantitative 1.

October 17, 2024
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factors that led you to file under Item 1.05 of Form 8-K. In this regard, we note the
adopting release states that “…investors are best served knowing … what led
management to conclude the incident is material.”

            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.
            Please contact Geoffrey Kruczek at 202-551-3641 or James Lopez at 202-551-3536
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences