SecProbe.io

September 29, 2010

Mr. Larry Reimert Co-Chief Executive Officer Dril-Quip, Inc. 13550 Hempstead Highway
Houston, TX 77040

Re: Dril-Quip, Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2009
Filed February 26, 2010 Proxy Statement on Schedule 14A Filed April 8, 2010 Response Letter Dated August 26, 2010 File No. 1-13439
 Dear Mr. Reimert:
We have reviewed your filing and responses a nd 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 advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease 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 additional comments.     General

 1. We note your response to our prior comments 1 and 2 from our letter dated July 29, 2010.
Please provide risk factor di sclosure addressing the possibl e effects on the company from
the Deepwater Horizon incident, including the items addressed in our prior comment 1.

2. Further, please include risk factor disclosure  regarding the specific risks associated with
your activities in the Gulf of Mexico, includ ing the items addressed in our prior comment
2 from our letter dated July 29, 2010.

Mr. Larry Reimert Dril-Quip, Inc. September 29, 2010 Page 2

Schedule 14A

Base Salary, page 15

3. We note your response to our prior comment 6 from our letter dated July 29, 2010.
Please include disclosure of the specific elements of your actual financial results your
compensation committee compares with the annual budget in order to make its salary determinations.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management 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 provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of  the United States.

 Please contact Douglas Brown at (202) 551-3265 or, me at (202) 551-3611 with any
questions.
Sincerely,

 Anne Nguyen Parker Branch Chief