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CORRESP Filing

Helmerich & Payne, Inc.
Date: May 23, 2025 · CIK: 0000046765 · Accession: 0001104659-25-052419

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File numbers found in text: 333-287331

Date
May 23, 2025
Author
Debra R. Stockton
Form
CORRESP
Company
Helmerich & Payne, Inc.

Letter

Helmerich & Payne, Inc.

222 North Detroit Avenue

Tulsa, Oklahoma 74120

(918) 742-5531

VIA EDGAR

May 23, 2025

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-3561

Re: Helmerich & Payne, Inc.

Registration Statement on Form S-4 (File No. 333-287331)

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the above-referenced Registration Statement on Form S-4 (File No. 333-287331) of Helmerich & Payne, Inc. (the "Registration Statement") so that it may become effective at 4:00 p.m., Eastern Time, on May 28, 2025, or as soon as possible thereafter.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform Hillary H. Holmes at Gibson, Dunn & Crutcher LLP, our external counsel, at (346) 718-6602.

Sincerely,
HELMERICH & PAYNE, INC.

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CORRESP
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 Helmerich & Payne, Inc.

 222 North Detroit Avenue

 Tulsa, Oklahoma 74120

 (918) 742-5531

 VIA EDGAR

 May 23, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549-3561

 Re:
 Helmerich & Payne, Inc.

 Registration Statement on Form S-4 (File No. 333-287331)

 Ladies and Gentlemen:

 Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the above-referenced
Registration Statement on Form S-4 (File No. 333-287331) of Helmerich & Payne, Inc. (the "Registration Statement")
so that it may become effective at 4:00 p.m., Eastern Time, on May 28, 2025, or as soon as possible thereafter.

 It would be appreciated if, as soon as the Registration
Statement is declared effective, you would so inform Hillary H. Holmes at Gibson, Dunn & Crutcher LLP, our external counsel,
at (346) 718-6602.

 Sincerely,

 HELMERICH & PAYNE, INC.

 /s/ Debra R. Stockton

 Debra R. Stockton

 Vice President and General Counsel

 cc:
 Hillary H. Holmes, Gibson, Dunn & Crutcher LLP

 Harrison C. Tucker, Gibson, Dunn & Crutcher
LLP