SEC Company Response from HALLIBURTON CO (HAL) (CIK 0000045012) (HAL) — Nov 29, 2011
HALLIBURTON CO (HAL) (CIK 0000045012)
Date: Nov. 29, 2011 · CIK: 0000045012 · Accession: 0001193125-11-324743
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-03492
Referenced dates: July 20, 2011, November 16, 2011
Letter
Via EDGAR Division of Corporation Finance United States Securities and Exchange Commission 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
e-mail on November 16, 2011.
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 enclosed.
Very truly yours,
BAKER BOTTS L.L.P.
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Correspondence Letter
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
BEIJING
DALLAS
DUBAI
HONG KONG
HOUSTON
LONDON
MOSCOW
NEW YORK
PALO ALTO
RIYADH
WASHINGTON
November 29, 2011
Via EDGAR
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
e-mail on November 16, 2011.
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 enclosed.
Very truly yours,
BAKER BOTTS L.L.P.
By: /s/ Eric C.
Swanson
Eric C. Swanson
Enclosures
cc:
Mr. Mark A. McCollum (Halliburton Company)
3000 North Sam Houston Parkway East
Houston, Texas 77032
Telephone: 281.871.2699
November 29, 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 November 16, 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
e-mail on November 16, 2011 relating to Halliburton Company’s (“us,” “we,” or “our”) Form 10-K 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
Risk Factors, page 6
1.
We note your responses to comments 2 and 3 from our letter dated July 20, 2011 as well as your risk factor discussion at page 7 under “Certain matters
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 procedures and historical experience with your hydraulic fracturing operations and comment 3 regarding your potential liability, please
confirm that you believe your current risk factor disclosure addresses all your material risks and that there are no material operational and financial risks stemming from your fracking operations that require disclosure hereunder.
Response: We confirm that we believe our current risk factor disclosure, including the disclosure in
our Form 10-Q for the quarter ended September 30, 2011, addresses all of our material risks stemming from our hydraulic fracturing operations and that there are no material operational or financial risks stemming from those operations that
require additional disclosure.
2.
If you believe that there are no specific material operational and financial risks stemming from your hydraulic fracturing operations, please consider disclosing the
information from prior comments 2 and 3 to provide context for the absence of any such risk factor disclosure addressing the operational and financial risks stemming from your hydraulic fracturing operations, and to better explain your role in the
hydraulic fracturing process. In this regard, we note that at present, your business discussion only lists in a summary fashion the services you provide under your two segments.
Response: Beginning with our Form 10-K for the fiscal year ending December 31, 2011, we will disclose certain information
from our responses to your prior comments 2 and 3 to (i) provide context for our risk factor disclosure relating to our hydraulic fracturing operations and (ii) further explain our role in the hydraulic fracturing process.
Acknowledgements
We hereby acknowledge that:
•
We are responsible for the adequacy and accuracy of the disclosure in our Form 10-K;
•
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Form
10-K; and
•
We 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.
Please call Eric C. Swanson or Andrew M. Baker of Baker Botts L.L.P. at (713) 229-1856
or (214) 953-6735, respectively, if you have any questions.
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