SEC Comment Letter for Helmerich & Payne, Inc. (HP) (CIK 0000046765) (HP) — Jan 27, 2012
Helmerich & Payne, Inc. (HP) (CIK 0000046765)
Date: Jan. 27, 2012 · CIK: 0000046765 · Accession: 0000000000-12-004597
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January 27, 2012 Via E-mail Mr. Hans Helmerich President and Chief Executive Officer Helmerich & Payne, Inc. 1437 S. Boulder Ave., Suite 1400 Tulsa, Oklahoma 74119-3623 Re: Helmerich & Payne, Inc. Form 10-K for Fiscal Ye ar Ended September 30, 2011 Filed November 23, 2011 Preliminary Proxy Statement on Schedule 14A Filed January 5, 2012 File No. 1-04221 Dear Mr. Helmerich: We have completed our review of your f ilings. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ A.N. Parker for H. Roger Schwall Assistant Director