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United States securities and exchange commission logo





                            June 3, 2024

       Jeffrey J. Bird
       Chief Executive Officer
       Dril-Quip, Inc.
       v2050 West Sam Houston Parkway S., Suite 1100
       Houston, Texas 77042

                                                        Re: Dril-Quip, Inc.
                                                            Form 10-K filed on
February 27, 2024
                                                            File No. 001-13439

       Dear Jeffrey J. Bird:

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

       Form 10-K filed on February 27, 2024

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations, page 43

   1.                                                   You present total
segment operating income which is a non-GAAP measures and should
                                                        be reconciled to the
most directly comparable GAAP measure. However, once reconciled
                                                        it would appear such a
measure may include adjustments that are inconsistent with the
                                                        applicable nonGAAP
guidance. In this regard, adjusting for    Corporate    expenses appears
                                                        to present nonGAAP
measures that exclude normal, recurring, cash operating expenses.
                                                        Therefore, please
revise to remove these measures from your periodic filings or tell us
                                                        why you believe the
measure is properly disclosed. Refer to Item 10(e)(1)(i)(B) of
                                                        Regulation S-K and
Questions 100.01 and 104.04 of the non-GAAP C&DIs.
   2.                                                   We note that you are
presenting a table that discloses your revenues and operating income
                                                        (loss) by business
segments. However, we note that you do not include a discussion and
                                                        analysis of each of the
segment's operating income(loss). Please describe your
                                                        consideration whether a
discussion of segment information would be necessary to an
                                                        understanding of your
business. We refer you to Item 303(b) of Regulation S-K.
 Jeffrey J. Bird
Dril-Quip, Inc.
June 3, 2024
Page 2
Consolidated Financial Statements
Note 6. Revenue Recognition, page 70

3.       Please revise in future filings the table to segregate revenue
recognized under ASC 606
         from that recognized under ASC 842. In this regard, we note that the
footnote table is
         describe as "Revenues from contracts with customers". We refer you to
ASC 606-10-50-
         4(a). In addition, the contract balances should be separately
disclosed from lease assets.
         We refer you to ASC 606- 10-50-8.
Note 9. Restructuring and other charges, page 71

4.       We note your disclosure that you "shifted from manufacturing in-house
to a vendor
         outsourcing model which resulted in inventory write-downs of
approximately $19.3
         million". Additionally, you state " as part of the 2021 global
strategic plan [you]
         discontinued certain product categories which resulted in inventory
write-downs...of
         approximately $47.7 million". Please be advised 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 advised or revise.
Note 12. Leases and Lease Commitments, page 73

5.       You disclose that most of your leases do not provide an implicit rate
and you use an
         estimated incremental borrowing rate based on the information
available at the lease
         commencement date in determining the present value of lease payments.
Please clarify
         whether the rates implicit in your leases as a lessee are not readily
determinable and if that
         is the basis for using your incremental borrowing rate as the discount
rate for your leases.
         Refer to    Rate Implicit in the Lease    defined in ASC 842-20-20.
Note 13. Business Segments, page 75

6.       Please revise future filings to reconcile the segment operating
income(loss) to
         consolidated income(loss) before income taxes pursuant to ASC
280-10-50-30(b).
       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.

       Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at
202-551-3488 with
any questions.



FirstName LastNameJeffrey J. Bird                               Sincerely,
Comapany NameDril-Quip, Inc.
June 3, 2024 Page 2                                             Division of
Corporation Finance
FirstName LastName                                              Office of
Technology
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