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                            April 14, 2023

       Christopher Baker
       President & Chief Executive Officer
       KLX Energy Services Holdings, Inc.
       3040 Post Oak Boulevard, 15th Floor
       Houston, Texas 77056

                                                        Re: KLX Energy Services
Holdings, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed April 7, 2023
                                                            File No. 333-271182

       Dear Christopher Baker:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you
       that the company and its management are responsible for the accuracy and
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

                                                        Please contact Claudia
Rios, Staff Attorney, at (202) 551-8770 with any questions.




                            Sincerely,


                            Division of Corporation Finance

                            Office of Energy & Transportation
       cc:                                              Katherine Terrell
Frank, Esq.