SEC Comment Letter for Helmerich & Payne, Inc. (HP) (CIK 0000046765) (HP) — Jul 1, 2015
Helmerich & Payne, Inc. (HP) (CIK 0000046765)
Date: July 1, 2015 · CIK: 0000046765 · Accession: 0000000000-15-034327
AI Filing Summary & Sentiment
File numbers found in text: 333-205219
Letter
June 30 , 2015 John W. Lindsay Chief Executive Officer Helmerich & Payne, Inc. 1437 S. Boulder Ave. Suite 1400 Tulsa, OK 74119
Re: Helmerich & Payne, Inc. Registration Statement on Form S-4 Filed June 25, 2015 File No. 333-205219
Dear Mr. Lindsay :
This is to advise you that we have not reviewed and will not review your registration statement .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 1933 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In the event you request acceleration of the effective date of the pending registration statement, please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
John W. Lindsay Helmerich & Payne, Inc. June 30 , 2015 Page 2
Please refer to Rules 460 and 461 regarding requests for acceleration. We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchang e Act of 1934 as they relate to the proposed public offering of the registered securities.
Please contact Paul Monsour , Staff Attorney, at (202) 551-3360 with any questions.
Sincerely,
/s/ Loan Lauren P. Nguyen for
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June 30 , 2015 John W. Lindsay Chief Executive Officer Helmerich & Payne, Inc. 1437 S. Boulder Ave. Suite 1400 Tulsa, OK 74119 Re: Helmerich & Payne, Inc. Registration Statement on Form S-4 Filed June 25, 2015 File No. 333-205219 Dear Mr. Lindsay : This is to advise you that we have not reviewed and will not review your registration statement . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 1933 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In the event you request acceleration of the effective date of the pending registration statement, please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. John W. Lindsay Helmerich & Payne, Inc. June 30 , 2015 Page 2 Please refer to Rules 460 and 461 regarding requests for acceleration. We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchang e Act of 1934 as they relate to the proposed public offering of the registered securities. Please contact Paul Monsour , Staff Attorney, at (202) 551-3360 with any questions. Sincerely, /s/ Loan Lauren P. Nguyen for H. Roger Schwall Assistant Director cc: Ms. Katherine D. Ashley, Esq.