SecProbe.io

June 30 , 2014

Via E -mail
Jerry M. Brooks
Vice President  — Finance and Chief Financial Officer
Dril-Quip, Inc.
6401 N. Eldridge Parkway
Houston, Texas  77041

 Re: Dril-Quip, Inc.
  Form  10-K for Fiscal Year Ended December 31, 2013
  Filed February 28, 2014
  File No. 1 -13439

Dear Mr. Brooks :

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we may
better understand yo ur disclosure.

Please respond to this letter within ten business days 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, please  tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

General

1. On page 10 of the 10 -K, you state that Petrobras accounted for approximately 11%, 12%
and 15% of your total revenues in 2013, 2012 and 2011, respectively.  News reports
indicate that Petrobras has overseas interests in countries including Cuba and is working
in Sudan.  Y ou state on page 5 that your operations are organized into geographic
segments that inc lude Africa and the Middle East, regions that include Sudan and Syria .

Cuba, Sudan and Syria are designated by the Department of State as state sponsors of
terrorism, and are subject to U.S. economic sanctions and export controls.  Your 10 -K
does not in clude disclosure about contacts with those countries.  Please describe to us the
nature and extent of your past, current, and anticipated contacts with Cuba, Sudan and
Syria, if any, whether through subsidiaries, affiliates, customers or other direct or in direct
arrangements.  Your response should describe any services, products, information or

Jerry M. Brooks
Dril-Quip , Inc.
June 30 , 2014
Page 2

 technology you have provided to Cuba, Sudan or Syria, directly or indirectly, and any
agreements, commercial arrangements, or other contacts you have had with the
governments of those countries or entities controlled by their governments.

2. Please discuss the materiality of any contacts with Cuba, Sudan and Syria described in
response to the foregoing comment, and whether those contacts constitute a material
investment  risk for your security holders.  You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets, and
liabilities for the last three fiscal years and the subsequent interim period.  Also, a ddress
materiality in terms of qualitative factors that a reasonable investor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value.  Various state and muni cipal
governments, universities, and other investors have proposed or adopted divestment or
similar initiatives regarding investment in companies that do business with U.S. -
designated state sponsors of terrorism.  Your materiality analysis should address t he
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations associated with Cuba, Sudan and Syria.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the fi ling 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 the company’s disclosure, they a re 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 proceedin g initiated by
the Commission or any person under the federal securities laws of the United States.

Jerry M. Brooks
Dril-Quip , Inc.
June 30 , 2014
Page 3

Please contact Daniel Leslie, Staff Attorney, at (202) 551 -3876  or me at (202) 551 -3470
if you have any questions about the comments or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Roger Schwall
  Assistant Director
 Division of Corporation Finance

 James C. Webster
 Vice President,
General Counsel and Secretary
 Dril-Quip, Inc.