November 19, 2012
MEMORANDUM
TO: | Division of Corporation Finance, Securities and Exchange Commission | |
FROM: | McDermott International, Inc. | |
RE: | Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2011 (File No. 1-08430) | |
Response to Staff Comments |
This memorandum is being submitted in response to the SEC Staffs letter dated October 17, 2012 and after several discussions with members of the Staff, including our most recent conference call with members of the Staff on November 8, 2012. Based on those discussions, in future filings, to the extent that changes in estimates materially impact McDermotts consolidated results in a reporting period, McDermott will disclose and discuss those changes in estimates, including their impact on results, in MD&A. McDermott would do this whether the changes in estimates that materially impacted results related to an individual contract or to multiple contracts.
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