View:
[Missing Graphic Reference]
1401
McKinney, Suite 2400, · Houston, Texas 77010
Phone
713.759.2600
Margaret
E. Carriere
Senior
Vice President and Corporate Secretary
June
16,
2006
VIA
EDGAR, FACSIMILE (202) 942-9579 and U.S. Mail
Cecilia
D. Blye, Chief
Office
of
Global Security Risk
United
States
Securities
and Exchange Commission
100
F.
St. N.E.
Washington,
D.C. 20549-5546
Reference: Halliburton
Company
Form
10-K for the Fiscal Year Ended December 31, 2005
Filed
March 13 2006
File
No. 001-03492
Dear
Ms.
Blye:
This
is
in response to your letter addressed to our President and CEO, David J. Lesar,
dated June 9, 2006.
Response
to Follow Up
Syria
The
company has no active operations in Syria. As explained in our letter of May
26,
2006, no sales have been made thus far for 2006, nor is there any intention
to
make such sales.
As
announced internally in a Corporate Business Practice effective March 31, 2005,
the company’s intention was not to undertake further sales to Syria once
existing commitments were fulfilled. We believe that all such commitments have
been fulfilled, but would consider any situation according to its unique facts
and circumstances, if a customer on a prior contract should make a request
for a
product or service under such pre-existing commitment, in all cases subject
to
appropriate licenses and permissions from authorities having jurisdiction.
Any
such request that might be made is unlikely to be material in an economic
sense.
We
believe that there is no impact on investors or investor sentiment relating
to
activities in Syria. We are not aware that any person or entity has made the
decision to invest or not to invest in Halliburton based on activity in Syria,
nor do we think it likely that they would do so.
If
you
have questions, please call me at 713-759-2617.
Sincerely
yours,
/s/
Margaret Carriere
Margaret
Carriere