United States securities and exchange commission logo

                              September 21, 2022

       Eric Carre
       Executive Vice President, Chief Financial Officer
       Halliburton Company
       3000 North Sam Houston Parkway East
       Houston, TX 77032

                                                        Re: Halliburton Company
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Response dated
September 9, 2022
                                                            File No. 001-03492

       Dear Mr. Carre:

              We have reviewed your September 9, 2022 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       August 25, 2022 letter.

       Response dated September 9, 2022

       Risk Factors, page 9

   1.                                                   We note your response
to prior comment 2 states that climate change transition
                                                        considerations are not
the only source of technology transition risks and are not more
                                                        significant than other
factors that give rise to these types of risks. In that regard, your
                                                        response indicates that
climate change technology transition risks are mitigated by your
                                                        emissions reduction
goal and that technology risks related to such goal are not unique to
                                                        climate change. Please
explain with greater specificity how you assessed climate change
                                                        technology transition
risks and credit risks as opposed to other risks for purposes of
                                                        disclosure in your SEC
 Eric Carre
Halliburton Company
September 21, 2022
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations,, page

2.       We note your response to prior comment 5. However, it does not appear
that you have
         addressed the specific elements of our prior comment or explained the
basis for your
         conclusion regarding materiality. Please explain in greater detail how
you considered
         providing disclosure regarding the following indirect consequences of
         regulations or business trends:
             decreased demand for goods or services that produce significant
greenhouse gas
             emissions or are related to carbon-based energy sources;
             increased demand for goods or services that result in lower
emissions than competing
             increased competition to develop innovative new products that
result in lower
             emissions; and
             any anticipated reputational risks resulting from your operations
or products that
             produce material greenhouse gas emissions.
3.       We note your response to prior comment 6 states that you do not
believe that a weather
         event is likely to impact the global supply chain in a material way.
Please tell us how you
         considered the possible consequences to you from weather-related
disruptions to your
         customers and suppliers as part of your risk factor titled
"Constraints in the supply of,
         prices for and availability of transportation of raw materials can
have a material adverse
         effect on our business and consolidated results of operations" on page
11 of your Form
         10-K and your risk factor titled "If we lose one or more of our
significant customers or if
         our customers delay paying or fail to pay a significant amount of our
         receivables, it could have a material adverse effect on our business,
consolidated results of
         operations, and consolidated financial condition" on page 17 of your
Form 10-K.
       Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.

FirstName LastNameEric Carre                                   Sincerely,
Comapany NameHalliburton Company
                                                               Division of
Corporation Finance
September 21, 2022 Page 2                                      Office of Energy
& Transportation
FirstName LastName