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                                                             July 12, 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
            Response dated July 8, 2024
            File No. 001-13439
Dear Jeffrey J. Bird:

     We have reviewed your Form 10-K/A filed on July 8, 2024 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 June
28, 2024 letter.

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 note that the discussion of your results of operations for the year
ended December 31,
        2022 compared to the year ended December 31, 2021 is being incorporated
by reference
        to your 2022 Form 10-K. In light of your restatement to the 2021
financial statements,
        please tell us what consideration you gave to including a revised
discussion in your
        current MD&A for those periods.


2.      We note that the Adjusted EBITDA includes an adjustment for
restructuring and other
        charges for each of your reporting periods. We also note your Item 4.02
Form 8-K filed
        on July 8, 2024 states "Since the error is related to misclassification
on the Consolidated
        Statement of Income (loss), there was no impact on...   Adjusted EBITDA
  ". Since
 July 12, 2024
Page 2

       inventory write-downs are a cost of sales, please clarify why this
charge would still be
       adjusted in your calculation of Adjusted EBITDA. Considering the nature
of your
       business, adjustments to write off inventory appear to be normal
operating expenses. We
       refer you to Questions 100.01 in the Compliance and Disclosure
Interpretations on Non-
       GAAP Financial Measures.
Item 11. Executive Compensation, page 90

3.     We note that you checked the box indicating that error corrections to
your financial
       statements are restatements that required a recovery analysis of
incentive-based
       compensation received by any of your executive officers during the
relevant recovery
       period pursuant to   240.10D-1(b). Please tell us what consideration you
gave to
       disclosing your recovery analysis of awarded compensation pursuant to
your
       compensation recovery policy provided in Exhibit 97 of your Form 10-K.
We refer you to
       Item 402(w) of Regulation S-K. In addition, we remind you that any Item
402(w)
       disclosure should be provided in an Interactive Data File in accordance
with Rule 405 of
       Regulation S-T and the EDGAR Filer Manual.
       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
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