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    ONE SHELL PLAZA
910 LOUISIANA
HOUSTON, TEXAS
77002-4995

TEL +1 713.229.1234
FAX +1 713.229.1522
www.bakerbotts.com

    ABU DHABI

AUSTIN

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PALO ALTO

RIYADH

WASHINGTON

FOIA CONFIDENTIAL TREATMENT REQUEST

CONFIDENTIAL TREATMENT REQUESTED BY HALLIBURTON COMPANY

August 2, 2011

Via EDGAR (Redacted)

Via Overnight Mail and Fax (Including Confidential Portions)

Mr. H. Roger Schwall

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Halliburton Company

Form 10-K for Fiscal Year Ended December 31, 2010

Filed February 17, 2011

File No. 001-03492

Dear Mr. Schwall:

On behalf of Halliburton Company (“Halliburton”), we are transmitting a memorandum of Halliburton
responding to the comments received from the staff of the Division of Corporation Finance of the
Securities and Exchange Commission (the “Commission”) by facsimile dated July 20, 2011. The
memorandum does not include portions of Halliburton’s responses to Comments No. 1, 2 and 3 that
have been redacted and are subject to the below confidential treatment request. Accordingly, the
EDGAR submission of the memorandum does not contain portions for which confidential treatment is
requested. The location of information subject to the confidential treatment request is indicated
in the EDGAR submission with [****]. A complete paper copy of the memorandum, including the
portions for which confidential treatment is requested, is being provided supplementally to the
Commission herewith.

FOIA Confidential Treatment Request

Pursuant to Rule 83 of the Commission’s rules and regulations relating to Commission records and
information (17 C.F.R. 200.83), we hereby request that confidential treatment be accorded to the
aforementioned portions of the memorandum and that such material not be disclosed in response to
any inquiry under the Freedom of Information Act (5 U.S.C. § 552). Please promptly inform us of
any request under the Freedom of Information Act or otherwise so that we may substantiate this
request for confidential treatment according to Rule 83. In addition, we note that Rule 80(b)(4)
of the Commission’s rules and regulations (17 C.F.R. 200.80(b)(4)),

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    August 2, 2011

CONFIDENTIAL TREATMENT REQUESTED BY HALLIBURTON COMPANY

provides that replies to letters of comment of this nature are considered non public and that the
Commission will generally not publish them or make them available except for certain reasonably
segregable portions thereof after deletion of the portions considered non public.

All of the pages of the memorandum, including those containing the confidential portions, have been
marked with the following legend: “CONFIDENTIAL TREATMENT REQUESTED BY HALLIBURTON COMPANY” and
are numbered [HAL0001] through [HAL0009].

In addition to its request for confidential treatment of the above-referenced portion of the
memorandum, Halliburton requests that any memoranda, notes or other writings made by any member or
employee of the Commission relating thereto or any conference or telephone conversation with
respect thereto and any copies of extracts of any of the foregoing be withheld from public
availability pursuant to 5 U.S.C. §552(b)(3), (4) and (5), and 17 C.F.R. §200.80(b)(3), (4) and
(5).

A copy of this Confidential Treatment Request (without the memorandum) is being delivered to the
FOIA Office of the Commission.

Please contact the undersigned at the address listed above or telephone the undersigned
(713.229.1856) or Andrew M. Baker (214.953.6735) of the firm Baker Botts L.L.P., counsel to
Halliburton, with any questions or comments you may have regarding the Confidential Treatment
Request or the enclosed.

    Very truly yours,

BAKER BOTTS L.L.P.

    By:
                /s/ Eric C. Swanson

    Eric C. Swanson

Enclosures

    cc:

    Suying Li (Commission)

(Via Fax: 703.813.6982)

Office of Freedom of Information and Privacy Act Operations

Securities and Exchange Commission

100 F. Street, NE, Mail Stop 2736

Washington, DC 20549

(without enclosures)

Mr. Mark A. McCollum (Halliburton Company)

3000 North Sam Houston Parkway East

Houston, Texas 77032

Telephone: 281.871.2699

FOIA CONFIDENTIAL TREATMENT REQUEST

CONFIDENTIAL TREATMENT REQUESTED BY HALLIBURTON COMPANY

[HAL0001]

August 2, 2011

MEMORANDUM

    TO:

    Division of Corporation Finance

Securities and Exchange Commission

    FROM:

    Halliburton Company

    RE:

    Form 10-K for Fiscal Year Ended December 31, 2010

Filed February 17, 2011

File No. 001-03492

Response to Staff Comments dated July 20, 2011

     We are responding to comments received from the staff of the Division of Corporation Finance
(the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) by
facsimile dated July 20, 2011 relating to Halliburton Company’s
(“Halliburton,” “us,” “we,” or “our”) Form 10K for the
fiscal year ended December 31, 2010 filed with the Commission on February 17, 2011 (the “Form
10-K”).

     For your convenience, our responses are prefaced by the corresponding Staff comment in bold
text.

Form 10-K for Fiscal Year Ended December 31, 2010

General

    1.

    You discuss in your filing that your completion and production services include hydraulic
fracturing and acidizing services. Please tell us, with a view for disclosure:

    •

    what percentage of your services involves hydraulic fracturing;

    •

    your anticipated costs and funding associated with hydraulic fracturing
services; and

    •

    whether there have been any incidents, citations, or suits related to
your hydraulic fracturing operations for environmental concerns, and if so, what
your response has been.

    Response: Hydraulic fracturing revenue represented approximately [****]% of
Halliburton’s total revenue during the six months ended June 30, 2011. For the years ended
December 31, 2010, 2009 and 2008, hydraulic fracturing represented an estimated [****]%,
[****]% and [****]%, respectively, of Halliburton’s total revenue.

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CONFIDENTIAL TREATMENT REQUESTED BY HALLIBURTON COMPANY

[HAL0002]

    Hydraulic fracturing resides in the Production Enhancement product service line, which is
part of the Completion and Production division (reporting segment). Halliburton’s accounting
systems and processes do not track complete operating costs and expenses just for hydraulic
fracturing services. Rather, operating costs and expenses are accounted for at a product
service line level. For example, operating costs and expenses related to certain support
services, shared facilities and employees and research and development are not allocated to
hydraulic fracturing but rather to the applicable product service line (in this case, to
Production Enhancement). In order to provide some context, hydraulic fracturing represented
over [****]% of Production Enhancement’s revenue for the full year 2010 and the six months
ended June 30, 2011. Production Enhancement operating costs and expenses were approximately
$[****] in 2010 and approximately $[****] for the six months ended June 30, 2011. However,
specific operating costs and expenses related to hydraulic fracturing are not available.

    Similarly, capital expenditures are not tracked specifically for hydraulic fracturing.
Because much of the capital spent relates to more than one product service line, such as
real estate and manufacturing capacity, capital expenditures are accounted for at the
division level. Total capital expenditures for Completion and Production were $1.0 billion
and $[****] for 2010 and the six months ended June 30, 2011, respectively. Halliburton
believes that more than [****] of these expenditures related to hydraulic fracturing,
although a more precise figure is not available.

    Halliburton has not estimated operating costs and expenses or capital expenditures related
to hydraulic fracturing beyond 2011, although it expects that these amounts could continue
to grow if demand for hydraulic fracturing services increases.

    Halliburton has not been subject to any citations because of environmental concerns arising
from its hydraulic fracturing operations. In addition, Halliburton is unaware of any
incident in which its hydraulic fracturing operations caused substantial environmental
concerns. Halliburton, along with other operators and service companies, has been named in
a few lawsuits where plaintiffs allege that contamination emanated from drilling operations,
but Halliburton has no reason to believe that its activities at the respective drilling
sites caused the alleged contamination. The Company is vigorously defending these actions.

    2.

    In regard to your hydraulic fracturing services and more generally the services you provide
in your completion and production segment, please also tell us what steps you have taken to
minimize any potential environmental 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:

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CONFIDENTIAL TREATMENT REQUESTED BY HALLIBURTON COMPANY

[HAL0003]

    •

    have steps or technology in place to ensure that the services you
provide for drilling, casing, cementing, and well completions 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 rate or pressure and/or
detection of fluid leak-off;

    •

    evaluate the environmental impact of additives to your frack 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.

    Response: As part of its hydraulic fracturing services, Halliburton generally
designs and implements the hydraulic fracturing operation at the direction of the operator
once the well has been drilled, cased and cemented. Halliburton provides various services
related to the casing and cementing of wells, although the specifications for the casing and
cementing of the well remain the responsibility of the operator. The operator is typically
Halliburton’s customer. The operator is generally responsible for providing the base fluid
(usually water) used in the hydraulic fracturing of a well. Halliburton supplies the
proppant and any additives used in the overall fracturing fluid mixture. In addition,
Halliburton will mix the additives and proppant with the base fluid and will pump the
mixture down the wellbore to create the desired fractures in the target formation. The
operator is responsible for the disposition of any materials that are subsequently pumped
out of the well, including flowback fluids and produced water.

    As part of the process of constructing the well, the operator will take a number of steps
designed to protect drinking water resources. In particular, the casing and cementing of
the well are designed to provide “zonal isolation” so that the fluids pumped down the
wellbore and the oil and natural gas and other materials that are subsequently pumped out of
the well will not come into contact with shallow aquifers or other shallow formations
through which those materials could potentially migrate to the surface. As recognized by
the U.S. Environmental Protection Agency (“EPA”), the Ground Water Protection Council and
state regulators, these “zonal isolation” techniques have been effective in protecting
drinking water resources. For example, EPA noted in its June 2004 report entitled Evaluation
of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed
Methane Reservoirs (at ES-13) that the Agency was aware of “no confirmed
cases [of contamination of underground sources of drinking water] that are linked to
fracturing fluid injection into CBM wells or subsequent underground movement of fracturing
fluids.” Likewise, EPA Administrator Lisa Jackson stated in May 24, 2011
testimony before the House Committee on Oversight and Government Reform that she is “not
aware of any water contamination associated with the recent drilling” in the Marcellus
Shale. Numerous state regulators have recently confirmed that they are not
aware of any instances of groundwater contamination due to hydraulic fracturing in their
states. See New York State Department of Environmental Conservation, Preliminary

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CONFIDENTIAL TREATMENT REQUESTED BY HALLIBURTON COMPANY

[HAL0004]

    Revised Draft, Supplemental Generic Environmental Impact Statement on the Oil, Gas and
Solution Mining Regulatory Program, Well Permit Issuance for Horizontal Drilling And
High-Volume Hydraulic Fracturing to Develop the Marcellus Shale and Other Low-Permeability
Gas Reservoirs, Appendix 15, available at http://www.dec.ny.gov/energy/75370.html.

    Halliburton has taken and continues to take a variety of steps in an effort to ensure that
the services it provides in connection with the casing, cementing and stimulation of oil and
natural gas wells are conducted in accordance with the highest industry standards. These
steps include the following:

    •

    The Halliburton Management System (“HMS”) — HMS is a quality and design
assurance program that is designed to integrate key components of Halliburton’s
business practices, including company policies, design standards, operating
procedures and work methods, into a single online system to guide employees. This
system provides a framework for our global operations personnel to follow, by job
type, in order to achieve consistent service delivery on location, regardless of
geography. HMS includes a Health, Safety and Environment (“HSE”) component
designed to protect the public health and the environment. HMS is continually
updated to reflect newly established Halliburton and industry best practices,
industry advancements and site-specific challenges.

    HMS not only encompasses a comprehensive set of procedures, checklists, forms and
other documents providing guidance on conducting efficient and safe work practices,
but the system also contains components designed to monitor and continuously improve
performance. Halliburton personnel perform a number of audit functions, including
audits of operational activities, HSE processes and practices and the HMS itself.
Results are reported to management personnel who direct the response to any concerns
revealed by the audit. Another component of HMS is Correction, Prevention &
Improvement (“CPI”). CPI provides near real-time visibility of performance issues
and metrics. It includes a risk assessment function and allows Halliburton to plan,
prioritize and coordinate corrective actions. The feedback our managers and
employees receive from the CPI program supports our goal of continuous improvement
in the HSE arena and throughout the company.

    •

    Participation in industry organizations — Halliburton is an active
participant in and sponsor of a number of key industry-recognized technical
exchange organizations. Technical experts within each of our service lines are
regularly invited to share Halliburton best practices and technological
advancements within these forums. Two examples of such organizations are the
Society of Petroleum Engineers and the American Petroleum Institute (“API”). API
has recently issued several standards regarding the conduct of hydraulic fracturing
operations. Halliburton
participated in the development of these standards. Halliburton has likewise
participated in the development of API-recommended practices for cementing.

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CONFIDENTIAL TREATMENT REQUESTED BY HALLIBURTON COMPANY

[HAL0005]

    •

    Global Laboratory Best Practices — Halliburton’s laboratory facilities
operate in conformance with the Ha