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CORRESP
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      Response to SEC Inquiry 020806

    [Missing Graphic Reference]

    1401
      McKinney, Suite 2400, · Houston, Texas 77010

    Phone
      713.759.2600

    Margaret
      E. Carriere

    Senior
      Vice President and Corporate Secretary

    February
      8, 2006

    VIA
      EDGAR, FACSIMILE (202) 942-9579 and U.S. Mail

    Cecilia
      D. Blye, Chief

    Office
      of
      Global Security Risk

    United
      States

    Securities
      and Exchange Commission

    100
      F.
      St. N.E.

    Washington,
      D.C. 20549-5546

    Reference: Halliburton
      Company

    Form
      10-K for the Fiscal Year Ended December 31, 2004

    Filed
      March 1, 2005

    File
      No. 001-03492

    Dear
      Ms.
      Blye:

    This
      is
      in response to your letter addressed to our President and CEO, David J. Lesar,
      dated December 30, 2005.

    Response
      to Comments 1, 2 and 3

    Libya

    Activities
      in Libya occur through the Libyan Branch of Halliburton G.m.b.H., a German
      corporation headquartered in Celle, Germany. The Libyan Branch of Halliburton
      G.m.b.H. had revenue of approximately $31 million in 2004 for conventional
      oil
      field services work in Libya. Approximately 185 employees work in Libya for
      this
      German corporation. With the lifting of Libyan sanctions in 2004, this German
      corporation is attempting to increase its activities to include more specialized
      drilling services. We estimate revenues for 2005 to be about $40 million.
      Oilfield software supplied by our Landmark Graphics unit is being provided
      to
      worldwide customers, some of whom use it for operations in Libya.

    Brown
      and
      Root (NA) Limited, a British Virgin Islands ( BVI) corporation, is a 50 - 50
      joint venture with another BVI entity ultimately owned by the Libyan government.
      The company operates mostly in Libya. It is in the final stages of providing
      engineering assistance on the Great Man Made River Project, a project to provide
      irrigation to desert areas in Libya. Nothing is exported from the United States
      to support this project. Historical KBR share of operational revenue has ranged
      as high as $10 - $20 million annually, but was only $4 to $5 million for 2004
      and 2005. KBR, the Halliburton subsidiary which manages this investment, intends
      to divest itself of its 50% shareholding in Brown & Root (NA) Ltd in the
      first half of 2006.

    All
      Libyan revenues combined were less than $40 million for 2004, or less than
      one
      quarter of 1% of the company’s revenue. Particularly in light of the small scale
      of activities, we see no negative impact on shareholders or investors. We do
      not
      believe our contracts with Libya constitute a material investment risk to our
      shareholders. We are not aware that any person or entity has made the decision
      to invest or not to invest in Halliburton based on activity in Libya, nor do
      we
      think it likely that they would do so.

    Syria

    The
      company has no active operations in Syria. Effective January 31, 2005, the
      company announced that it would cease to undertake new work in Syria, subject
      to
      completing existing contractual commitments. Sales to Syria for 2004 were only
      $453 thousand, all consisting of Landmark Graphics oilfield software. Sales
      for
      2005 declined to $21 thousand, again consisting of Landmark Graphics oilfield
      software. These Syrian sales represent less than one one-hundredth of 1% of
      the
      company’s revenue for the periods discussed. No sales are anticipated for 2006.
      We believe that there is no impact on investors or investor sentiment relating
      to activities in Syria.

    If
      you
      have questions, please call me at 713-759-2617.

    Sincerely
      yours,

    /s/
      Margaret Carriere

    Margaret
      Carriere