SecProbe.io

December 23, 2013

Via Facsimile
Mr. H. Richard Walton
Executive Vice President
Flotek Industries, Inc.
10603 W. Sam Houston Parkway N. #300
Houston, Texas 77064

Re: Flotek Industries , Inc.
 Form 10-K for Fiscal Year Ended December 31, 2012
Filed March 13, 2013
File No. 1 -13270

Dear Mr. Walton :

We have reviewed your filing  and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comme nts apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additio nal comments.

Form 10 -K for Fiscal Year Ended December 31, 2012

Critical Accounting Policies and Estimates, page 31

Income Taxes, page 34

We note you reversed $18.6 million of your deferred tax asset valuation allowance in fiscal year
2012.  Your dis closure in Note 12 indicates this determination was based on consideration of the
objectively verifiable positive evidence for projecting future income, which included primarily
determining the average of the pre -tax income of the current and prior two yea rs after adjusting
for certain items not indicative of future performance.  Given the impact of the reversal of the
valuation allowance on your 2012 net income, please expand your disclosure in future filings to
quantify and discuss the material positive a nd negative evidence you considered, along with how
it was weighed, in determining that it is more likely than not that your deferred tax assets will be
realized.  Refer to the guidance in ASC 740 -10-30-16 through 30 -25.

Mr. H. Richard Walton
Flotek Industries, Inc.
December 23, 2013
Page 2

 Closing Comments

We urge all perso ns 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 Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its manage ment 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 responding to our comments, please provide  a written statement from the company
acknowledgi ng that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact  Tracie Towner at (202) 551 -3744  if you have questions regarding
comments on the financial  statements and related matters.  Please contact me at (202) 551 -3355
with any other questions.

Sincerely,

 /s/ Terence O ’Brien

 Terence O’Brien
Branch Chief