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June 28, 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 filed on
February 27, 2024
Correspondence
filed on June 24, 2024
File No. 001-13439
Dear Jeffrey J. Bird:
We have reviewed your June 25, 2024 response to our comment
letter and have the
following comment.
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 June 3, 2024 letter.
Form 10-K for the year ending December 31, 2023
Note 9. Restructuring and other charges, page 71
1. We note your response
to prior comment 4 and continue to believe that inventory
markdowns should be
classified in the income statement as a component of costs of goods
sold. We refer you to
ASC 420-10-S99-3. Please amend your Form 10-K for the year
ending December 31,
2023.
Jeffrey J. Bird
Dril-Quip, Inc.
June 28, 2024
Page 2
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.
FirstName LastNameJeffrey J. Bird Sincerely,
Comapany NameDril-Quip, Inc.
Division of Corporation
Finance
June 28, 2024 Page 2 Office of Technology
FirstName LastName