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November 8, 2023
Alf Melin
Executive Vice President and Chief Financial Officer
TechnipFMC plc
Hadrian House, Wincomblee Road
Newcastle Upon Tyne, United Kingdom
Re:TechnipFMC plc
Form 10-K for the Year Ended December 31, 2022
Form 10-Q for the Quarterly Period Ended September 30, 2023
Form 8-K furnished on October 26, 2023
File No. 001-37983
Dear Alf Melin:
            We have reviewed your November 6, 2023 response to our comment letter and have the
following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our October 6, 2023
letter.
Form 10-Q for the Quarterly Period Ended September 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Segment Results of Operations, page 36
1.We note your response to prior comment 1 and the revised disclosures in your September
30, 2023 Form 10-Q. Such revisions appear to focus on quantifying the change in revenue
for various geographic regions, however, the drivers behind such changes remain unclear.
While you state that a discussion of specific projects or product line details may cause
competitive harm or negatively impact negotiation with your customers, tell us your
consideration to include a qualitative discussion of how certain projects or product lines
impacted revenue in such regions. Alternatively, tell us what other drivers impacted
revenue for the geographic regions discussed and include a quantified discussion of such
drivers, where possible.

 FirstName LastNameAlf Melin
 Comapany NameTechnipFMC plc
 November 8, 2023 Page 2
 FirstName LastName
Alf Melin
TechnipFMC plc
November 8, 2023
Page 2
Form 8-K Furnished on October 26, 2023
Exhibit 99.1
Reconciliation of GAAP to non-GAAP Financial Measures, page 1
2.We note from your response to prior comment 4 that you did not record the tax effect for
certain non-GAAP adjustments, such as impairment charges and loss from investment in
Technip Energies, due to the fact that these adjustments relate to jurisdictions that had net
operating loss carryforwards (NOL) and/or a full valuation allowance against the deferred
tax assets. Please clarify whether your reference to the NOLs and valuation allowance is
based on the non-GAAP tax position in such jurisdictions. In this regard, to the extent
these jurisdictions had GAAP net losses but non-GAAP net income, tell us how you
determined that the NOLs and valuation allowance would apply to the non-GAAP
measure such that at tax adjustment was not necessary.
3.We note the revised non-GAAP reconciliation that you propose to include in future
filings. Please explain further the inclusion of the subtotal for "adjusted operating profit"
in this reconciliation and what it is intended to convey. In this regard, as presented
adjusted operating income is not reconciled to the most directly comparable GAAP
measure of operating income. Therefore, please remove this subtotal from your proposed
reconciliation. To the extent you want to present a measure for non-GAAP operating
income, provide a separate reconciliation for such measure that begins with GAAP
operating income.
            Please contact Chen Chen at 202-551-735 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Julia Thompson