SecProbe.io

Mail Stop 4628
 August 24 , 2018

Via E -Mail
Mark W. Smith
Chief Financial Officer
Helmerich & Payne, Inc.
1437 S. Boulder Ave., Suite 1400
Tulsa, Oklahoma 74119

Re: Helmerich &  Payne, Inc.
Form 10-K for Fiscal Year Ended September 30, 2017
 Response Dated July 23 , 2018
File No. 001-04221

Dear Mr. Smith :

We have reviewed  your July 23 , 2018  response to our comment  letter  and have the
following comment s.  In some of our comments , we may ask you to provide us with information
so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respon d.  If you  do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.
Unless we note otherwise, our references to prior comme nts are to comments in our June 22 , 2018
letter .

Form 10 -K for Fiscal Year Ended September 30, 2017

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 31

Critical Accounting Policies and Estimates , page 41
Impairment of Long -lived Assets and Finite -lived Intangibles, page 41

1. Based on the information provided in your responses to prior comments 2 and 3, it appears
that the estimates and assumptions made in connection with the impairment recoverability
test f or your Domestic FlexRig 4 asset group may be material due to the levels of
subjectivity and judgment associated with the estimates and assumptions, the susceptibility
of such matters to change, and the impact of the estimates and assumptions on your
finan cial condition or operating performance.  Accordingly, additional disclosure regarding

Mark W. Smith
Helmerich &  Payne, Inc.
August 24 , 2018
Page 2

 estimates and assumptions, such as those related to rig utilization levels and rig margins,
may be necessary to comply with the requirements of Item 303(a)(3)(ii) of Reg ulation S -K,
which requires a description of a known uncertainty.  Additional guidance appears in
Section V of Release 33 -8350, which states that MD&A should address the material
implications of uncertainties associated with the methods, assumptions, and e stimates
underlying critical accounting measurements.

Examples of additional disclosures include:

 The carrying value of the assets subject to impairment testing;

 A description of the methods and key assumptions used and how the key assumptions
were determined;

 A discussion of the degree of uncertainty associated with the key assumptions; and,

 A description of potential events and/or changes in circumstances that could reasonably
be expected to negatively affect the key assumptions.

You may contact  Jeannette Wong, Staff Accountant , at (202) 551 -2137  or Kimberly
Calder, Assistant Chief Accountant,  at (202) 551 -3701  with any questions.

Sincerely,

 /s/ Brad Skinner for

Ethan Horowitz
Accounting Branch Chief
Office of Natural Resources