July 22, 2024

Jeffrey J. Bird
Chief Executive Officer
Dril-Quip, Inc.
2050 West Sam Houston Parkway S., Suite 1100
Houston, Texas 77042

        Re: Dril-Quip, Inc.
            Form 10-K/A for Fiscal Year Ended December 31, 2023
            Correspondence filed on July 15, 2024
            File No. 001-13439
Dear Jeffrey J. Bird:

       We have reviewed your July 15, 2024 response to our comment letter and
have the
following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to this letter, we may have additional
comments. Unless we
note otherwise, any references to prior comments are to comments in our July
12, 2024 letter.

Correspondence filed on July 15, 2024
Form 10-K/A for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations,
page 41

1.      We have considered your response to prior comment 1, and we believe
that given the
        material impact that the reclassification of the inventory write-downs
had on Cost of Sales
        and Restructuring in the Year Ending December 31, 2021, you should
revise your results
        of operation discussion of 2022 versus 2021 accordingly.
2.      We appreciate your response to prior comment 2 and understand that as
part of your
        restatement of previously issued financial statements for the year
ended December 31,
        2021, you reclassified inventory write-downs from "Restructuring and
other charges    to
        "Cost of sales" to comply with ASC 420-10-S99-3. However, we believe
that you should
        not exclude inventory write-downs from your non-GAAP measures for the
same reasons
        articulated in the staff   s position that inventory markdowns should
be classified in the
 July 22, 2024
Page 2

       income statement as a component of cost of goods sold. Decisions about
the timing,
       method, and pricing of dispositions of inventory generally are
considered to be normal,
       recurring activities integral to the management of the ongoing business.
Please revise to
       remove this non-GAAP adjustment in future filings.
       Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology