SecProbe.io

Mail Stop 4631
June 16 , 2017

Via E -mail
Mr. H. Richard Walton
Chief Financial  Officer
Flotek Industries , Inc.
10603 W. Sam Houston Parkway N., Suite 300
Houston, Texas 77064

Re: Flotek Industries , Inc.
 Form 10-K for the Year Ended December 31, 2016
Filed February 8, 2017
Form 10 -Q for the Period Ended March 31, 2017
Filed May 3, 2017
File No. 1 -13270

Dear Mr. Walton :

We have limited our review of your filing to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  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.

Form 10 -K for the Year Ended December 31, 2016

Critical Accounting Policies

Long -Lived Assets Other than Goodwill, page 36

1. Please help us better understand why the same factors that resulted in you testing the
long-lived assets of the Drilling Technologies and Production Technologies segments for
impairment, including declines in drilling rig count , would not also result in yo u testing
the Energy Chemistry Technologies and Consumer and Industrial Chemistry
Technologies segments for impairment given that they also serve the oil and gas industry.
We also note that you recorded a loss from operation s in both 2016 and the three mo nths
ended March 31, 2017 after presenting the Drilling Technologies and Production
Technologies segments as discontinued  and that there was a significant decrease in the
cash generated from  continuing operations from $25.4 million in 2015 to $2 million  in

Mr. H. Richard Walton
Flotek Industries, Inc.
June 16 , 2017
Page 2

 2016 and a further decrease resulting in cash used in operations during the 3 months
ended March 31, 2017.

Form 10 -Q for the Period Ended March 31, 2017

Capital Resources and Liquidity, page 30

2. Please expand your disclosures to better address how you determined that your current
sources of cash will be sufficient to meet your cash requirements over the next 12 months
in light of the following:
 You refer to your total liquidity as available borrowing capacity under the revolving
line of credit and a vailable cash.  It appears that both of these amounts decreased
from December 31, 2016 to March 31, 2017.  Specifically, cash and cash equivalents
decreased from $ 4.8 million at December 31, 2016 to $1.8 million at March 31, 2017
and the available borrowin g capacity decreased from $16.5 million at December 31,
2016 to $15.2 million at March 31, 2017 ; and
 Your net cash generated from operating activities decreased significantly  from $25.5
milli on during the year ended December 31, 2015 to $ 2.1 million during  the year
ended December 31, 2016.  You also reported net cash used in operations during the
period ended March 31, 2017 of $3 million.
Refer to Item 303(a)(1) and (2) of Regulation S -K.

3. We note that your amended credit facility entered into in February 2017 among other
things modified certain covenants and restrictions.  It is not clear if the covenant
modifications were made because of your inability to meet the prior covenant terms in
place.  In this regard, please disclose the actual ratios/am ounts as of each reporting date
for any material debt covenants for which it is reasonably likely that you will not be able
to meet or which could impact your ability to obtain additional debt or e quity financing to
a material extent.  See Sections I.D and IV.C of the SEC Interpretive Release No. 33 -
8350.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any revie w, comments, action or absence of
action by the staff.  If you have any questions regarding these comments, please direct them to
Nudrat Salik , Staff Accountant, at (202) 551 -3692 or, in her absence , Al Pavot, Staff Accountant,
at (202) 551 -3738 .

 Sincerely,

/s/ Terence O ’Brien

Terence O’Brien
       Accounting Branch Chief
Office of Manufacturing and Construction