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CORRESP
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 Helmerich & Payne, Inc.

 222 North Detroit Avenue

 Tulsa, Oklahoma 74120

 (918) 742-5531

 May 23, 2025

 VIA EDGAR TRANSMISSION

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: Helmerich & Payne, Inc.
Registration Statement on Form S-4 (File No. 333-287331)

 Ladies and Gentlemen,

 This letter is sent on behalf of Helmerich &
Payne, Inc., a Delaware corporation (the " Company "), in connection with the above referenced Registration
Statement on Form S-4 (the " Registration Statement ") filed with the Securities and Exchange Commission
(the " Commission ") pursuant to the Securities Act of 1933, as amended (the " Securities Act "),
relating to the Company's proposed offer to exchange (the " Exchange Offer ") (i) up to $350,000,000
aggregate principal amount of its 4.650% Senior Notes due 2027 (the "New 2027 Notes"), (ii) up to $350,000,000 aggregate
principal amount of its 4.850% Senior Notes due 2029 (the "New 2029 Notes") and (iii) up to $550,000,000 aggregate principal
amount of its 5.500% Senior Notes due 2034 (together with the New 2027 Notes and the New 2029 Notes, the "Exchange Notes")
that have, in each case, been registered under the Securities Act, for (i) up to $350,000,000 aggregate principal amount of its
4.650% Senior Notes due 2027 (the "Old 2027 Notes"), (ii) up to $350,000,000 aggregate principal amount of its 4.850%
Senior Notes due 2029 (the "Old 2029 Notes") and (iii) up to $550,000,000 aggregate principal amount of its 5.500% Senior
Notes due 2034 (together with the Old 2027 Notes and the Old 2029 Notes, the "Initial Notes") that are, in each case, outstanding
and unregistered. The Company is registering the Exchange Offer pursuant to the Registration Statement in reliance on the position enunciated
by the staff of the Commission (the " Staff ") in Exxon Capital Holdings Corp. , SEC no-action letter available
May 13, 1988, Morgan Stanley & Co. , SEC no-action letter available June 5, 1991, and Shearman &
Sterling , SEC no-action letter available July 2, 1993 (collectively, the "No-Action Letters"). The Company has not
entered into any arrangement or understanding with any person to distribute the Exchange Notes to be received in the Exchange Offer and,
to the best of the Company's information and belief, each person participating in the Exchange Offer will be acquiring the Exchange
Notes in its ordinary course of business and has no arrangement or understanding with any person to participate in the distribution of
the Exchange Notes to be received in the Exchange Offer. In this regard, the Company will make each person participating in the Exchange
Offer aware (through the Exchange Offer prospectus) that any person using the Exchange Offer to participate in a distribution of the Exchange
Notes to be received in the Exchange Offer (1) cannot rely on the Staff's position enunciated in the No-Action Letters or similar
letters of the Staff and (2) must comply with registration and prospectus delivery requirements of the Securities Act in connection
with any secondary resale transaction. The Company acknowledges that such a secondary resale transaction should be covered by an effective
registration statement containing the selling securityholder information required by Item 507 of Regulation S-K.

 The Company will include in the transmittal letter
or similar documentation to be executed by an Exchange Offer offeree in order to participate in the Exchange Offer a provision substantially
similar to the following provision:

 If the Exchange Offer offeree is a broker-dealer holding
Initial Notes acquired for its own account as a result of market-making activities or other trading activities, it must acknowledge that
it will deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of the Exchange Notes received
in respect of such Initial Notes pursuant to the Exchange Offer; however, by so acknowledging and by delivering a prospectus, a broker-dealer
will not be deemed to admit that it is an "underwriter" within the meaning of the Securities Act.

 The Company will also require that each participant
in the Exchange Offer furnish a representation in the transmittal letter or similar documentation that neither such participant nor, to
the actual knowledge of such participant, any other person receiving Exchange Notes from such participant, has any arrangement or understanding
with any person to participate in the distribution of the Exchange Notes.

 The Company will make each person participating
in the Exchange Offer aware and will make broker-dealers participating in the Exchange Offer aware (through the Exchange Offer prospectus)
that any broker-dealer that resells Exchange Notes that were received by it for its own account pursuant to the Exchange Offer and any
broker or dealer that participates in a distribution of such Exchange Notes may be deemed to be an "underwriter" within the
meaning of the Securities Act and must deliver a prospectus meeting the requirements of the Securities Act in connection with any resale
of such Exchange Notes.

 Please do not hesitate to contact the undersigned
at (918) 742-5531 with any questions or comments concerning this letter.

 [ Signature page follows ]

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 Kind regards,

 /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