RE:
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National Oilwell Varco, Inc. (the Company) | |
Form 10-K for Fiscal Year Ended December 31, 2009 | ||
Filed February 26, 2010 (2009 Form 10-K) | ||
File No. 1-12317 |
1. | We note your response to comment 1 from our letter dated July 23, 2010, and reissue the comment. Please revise your disclosure to clarify your relationship with the shipyard as described in your response dated June 8, 2010. In addition, please identify the shipyard. In that regard, we note your disclosure at page 22 of your annual report that you had revenues of 16.6% of total revenue from this customer for the year ended December 31, 2009, and that the loss of this customer or a significant reduction in its purchases could adversely affect your future revenues or earnings. See Item 101(c)(vii) of Regulation S-K. |
2. | We note your response to comment 2 from our letter dated July 23, 2010. Please provide the information requested in our prior comment 2 with respect to the applicable policy limits and deductibles, and briefly describe the exclusions referenced in your response. |
Sincerely, |
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/s/ Dwight W. Rettig | ||||
Dwight W. Rettig | ||||
Senior Vice President, General Counsel and Secretary |
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* | Portions omitted pursuant to a request for confidential treatment filed by National Oilwell Varco, Inc. separately with the SEC. |
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