SecProbe.io

July 11 , 2013

Via E -mail
Blake T. DeBerry
Chief Executive  Officer
Dril-Quip, Inc.
6401 N. Eldridge Parkway
Houston, TX 77041

Re: Dril-Quip, Inc.
Form 10-K for Fiscal Year Ended December 31, 2012
Filed February 28, 2013
File No. 1-13439

Dear  Mr. DeBerry :

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 comments 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 additional  comments.

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

Item 1. Business, page 4

General , page 4

1. We note that you have operations in the Middle East  within your Asia -Pacific geographic
segment.  Please tell us  the countries in the Mid dle East in which you operate.

Blake T. DeBerry
Dril-Quip, Inc.
July 11 , 2013
Page 2

 Management’s Discussion and Analysis  of Financial Condition and Results of Operations, page
28

Liquidity and Capital Resources, page 36

2. We note your explanation of the large swing in your 2012 operating cash flow as being
attributed to increases in both trade receivables and inventory.  Your explanation at page
37 that both trade receivables and inventory increased due to the effects of having longer -
term projects suggests  that the variance has occ urred only recently , when it appears that
these two balance sheet line items have been building for several years.  Given that you
expect to fill approximately 66% of your December 31, 2012 backlog in the next year, we
would not expect a prolonged buildup in these two balance s.  Please revise the sources
and uses of cash analysis within your liquidity and capital resources discussion to provide
qualitative reasons for these changes.  If you have provided this discussion elsewhere,
please provide a cross -reference to that disclosure here.  See Item 303(a)(1) and (2) of
Regulation S -K, Sections III and IV of the SEC Interpretive Release No. 33 -8350, and
Sections 501.03 and 501.13 of the Financial Reporting Codification for guidance.

Closing Comments

We urge all persons  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 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 provide a written  statement  from  the company
acknowledging  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.

Please contact Paul Monsour, Staff Attorney, at (202) 551 -3360, or, in  his absence,
Sirimal Mukerjee, Staff Attorney, at (202) 551 -3340 with any questions.

Sincerely,

/s/H. Roger Schwall

H. Roger Schwall
Assistant Director