Mail Stop 4628
                                                            June 22, 2018

Via E-Mail
Mark W. Smith
Chief Financial Officer
Helmerich & Payne, Inc.
1437 S. Boulder Ave., Suite 1400
Tulsa, Oklahoma 74119

       Re:    Helmerich & Payne, Inc.
              Form 10-K for Fiscal Year Ended September 30, 2017
              Response Dated May 16, 2018
              File No. 001-04221

Dear Mr. Smith:

       We have reviewed your May 16, 2018 response to our comment letter and
have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.
Unless we note otherwise, our references to prior comments are to comments in
our April 12,
2018 letter.

Form 10-K for Fiscal Year Ended September 30, 2017

Consolidated Balance Sheets at September 30, 2017 and 2016, page 50

1.     Reconcile the summary of rigs, by asset group, as provided in the
supplemental
       information captioned Exhibit III, to the carrying value of contract
drilling equipment for
       financial reporting purpose. Explain if your ten asset groups encompass
the entire
       contract drilling equipment population. In that regard, as of September
30, 2017, the cost
       of your contract drilling equipment as disclosed in the consolidated
balance sheet was
       $8.2 billion, accumulated depreciation on all property, plant and
equipment was $3.9
       billion and the net property, plant and equipment was $5.0 billion
whereas, the total
       carrying value in Exhibit III differs.
 Mark W. Smith
Helmerich & Payne, Inc.
June 22, 2018
Page 2

Notes to Consolidated Financial Statements, page 54

Note 1   Summary of Significant Accounting Policies, page 54

Valuation of Long-Lived Assets, page 56

2.     You disclose on page 2 of your Form 10-K that "the FlexRig4s are
designed to efficiently
       drill more shallow depth wells of between 4,000 and 18,000 feet."
Considering the
       disclosure in your Form 10-K regarding industry trends toward more
complex drilling
       and the accelerated retirement of less capable mechanical rigs, explain
in greater detail
       how the assumptions for the Domestic FlexRig4 asset group were
determined with
       respect to your rig utilization levels and rig margins in the near- and
longer-term. Tell us
       about objective evidence used in determining your material assumptions
and discuss the
       degree of uncertainty associated with these assumptions.

3.     Your Form 8-K dated April 26, 2018 includes a statement that as market
conditions are
       tightening for FlexRigs, average dayrates for your rigs in the U.S. Land
spot market are
       expected to accelerate. Discuss your more recent contract status, rig
utilization levels,
       and rig margins for the Domestic FlexRig4 asset group as of May 31, 2018
and compare
       to similar metrics as of September 30, 2017. As part of your response,
tell us whether
       you have conducted additional impairment evaluations, and for which
asset group(s),
       subsequent to September 30, 2017. Include a description of (i) current
events or changes
       in circumstances, if any, which affected the assumptions used in your
last impairment
       evaluation, and (ii) if additional testing was performed, identify
changes to your
       assumptions made as a result.

4.     We note from your Form 8-K dated November 16, 2017 that there is demand
for rigs
       capable of drilling more complex horizontal wells with longer laterals
and that you have
       the capability to upgrade your existing FlexRigs to super-spec capacity.
If the demand
       for super-spec rigs remains consistent, discuss management's plans to
upgrade the
       Domestic FlexRig4 asset group and describe the potential impact to your
liquidity and
       capital resources from the capital investment that would be necessary
for such upgrades.

       You may contact Jeannette Wong, Staff Accountant, at (202) 551-2137 or
Kimberly
Calder, Assistant Chief Accountant, at (202) 551-3701 with any questions.


                                                            Sincerely,

                                                            /s/ Ethan Horowitz

                                                            Ethan Horowitz
                                                            Accounting Branch
Chief
                                                            Office of Natural
Resources