United States securities and exchange commission logo





                           January 31, 2022

       Mark Smith
       Chief Financial Officer
       Helmerich & Payne, Inc.
       1437 South Boulder Avenue, Suite 1400
       Tulsa, Oklahoma 74119

                                                        Re: Helmerich & Payne,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended September 30, 2021
                                                            Filed November 18,
2021
                                                            Form 8-K Filed
November 17, 2021
                                                            File No. 001-04221

       Dear Mr. Smith:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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.

       Form 10-K for the Fiscal Year Ended September 30, 2021

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations for the Fiscal Years Ended September 30, 2021 and
2020, page 44

   1.                                                   We note you present and
discuss segment gross margin for each of your reportable
                                                        segments in addition to
segment operating income (loss) in both your Form 10-K and in
                                                        the press release
included in your Form 8-K filed on November 17, 2021. Please revise to
                                                        label segment gross
margin as a non-GAAP financial measure and provide the required
                                                        disclosures pursuant to
Item 10(e) of Regulation S-K or tell us why you believe segment
                                                        gross margin is not a
non-GAAP financial measure.
 Mark Smith
FirstName  LastNameMark
Helmerich &  Payne, Inc. Smith
Comapany
January 31,NameHelmerich
            2022          & Payne, Inc.
January
Page 2 31, 2022 Page 2
FirstName LastName
2.       We note you disclose    average active rigs    for each of your
reportable segments. We also
         note you provide    average active rigs per day    for each of your
reportable segments on
         page 8. Please clearly define these two metrics and how they are
calculated. Refer to
         SEC Release No. 33-10751.
Liquidity and Capital Resources
Operating Activities, page 49

3.       We note you present "operating net working capital" in discussing your
cash flows from
         operating activities. Please identify operating net working capital as
a non-GAAP
         financial measure and provide the required disclosures pursuant to
Item 10(e) of
         Regulation S-K. To the extent you do not believe this is a non-GAAP
measure, please
         explain.
Form 8-K Filed November 17, 2021

Exhibit 99.1
Select Items, page 13

4.       We note you disclose adjusted net loss for the three months ended
September 30, 2021,
         the three months ended June 30, 2021 and the year ended September 30,
2021. Please
         label adjusted net loss as a non-GAAP financial measure and provide
disclosures to
         comply with Item 10(e)(1)(i) of Regulation S-K or tell us why you
believe it does not
         represent a non-GAAP financial measure.
       In closing, 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.

       You may contact Steve Lo at 202-551-3394 or Craig Arakawa at
202-551-3650 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Energy &
Transportation