July 27, 2016 |
Securities and Exchange Commission |
Division of Corporation Finance |
100 F Street, N.E. |
Washington, D.C. 20549-4628 |
Attn: | Brad Skinner, Senior Assistant Chief Accountant |
Office of Natural Resources |
Re: | Weatherford International public limited company | |
Form 8-K furnished May 4, 2016 | ||
File No. 1-36504 |
1. | The news release provided under Exhibit 99.1 includes a table at page 2, together with an accompanying discussion of segment highlights, that presents and discusses non-GAAP amounts without an equally prominent presentation and discussion of GAAP amounts. This is inconsistent with the updated Compliance and Disclosure Interpretations the Division issued on May 17, 2016, particularly C&DI 102.10. Please review this guidance when preparing your next earnings release. |
2. | Discussion on page 7, under the caption “Reclassifications and Non-GAAP Financial Measures”, indicates that, unless explicitly stated to the contrary, all financial measures used throughout the document are non-GAAP. However, there are financial measures such as revenue which appear to be GAAP amounts but are not identified as such. Revise disclosure throughout the release to include clear, consistent identification of all GAAP and non-GAAP amounts. |
• | it 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 |
• | it 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. |
Very truly yours, | |||
Weatherford International plc | |||
Date: July 27, 2016 | By: | /s/ Krishna Shivram | |
Krishna Shivram | |||
Executive Vice President and | |||
Chief Financial Officer | |||
cc: | Sean T. Wheeler | ||
Latham & Watkins LLP |