August 14, 2024
Nancy Buese
Chief Financial Officer
Baker Hughes Company
575 N. Dairy Ashford Rd., Suite 100
Houston, TX 77079
Re: Baker Hughes Company
Form 10-K for the Fiscal Year Ended December 31, 2023
Response dated August 2, 2024
File No. 001-38143
Dear Nancy Buese:
We have reviewed your August 2, 2024 response to our comment letter 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 July
23, 2024 letter.
Form 10-K for the Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Fiscal Year 2023 to Fiscal Year 2022, page 37
1. In your response to prior comment 2 you state that the company intends
to provide
additional information on the nature and classification of material,
recurring charges such
as those reflected as Corporate expenses to further clarify how the
discussion on the
results of operations is reflected within the face of the income
statement. Please revise to
ensure your discussion of segment results focuses only on items included
within the
segment profit (loss) measure, and does not include items that are
presented in your ASC
280 reconciliation that are not attributed to the segments. In this
regard, we note that
Corporate expenses is not a line item on your Statements of Income
(Loss).
August 14, 2024
Page 2
Guarantor Information, page 43
2. We note your response to prior comment 3 that the company has no
subsidiaries the
obligations of which it guarantees that are subject to Section 13(a) or
Section 15(d) of the
Securities Exchange Act of 1934, as amended. Please further explain how
you arrived at
this conclusion. In this regard, we note previous disclosures by Baker
Hughes Holdings
LLC that the 5.125% Senior Notes due 2040 (the "Notes") were registered
on
an exchange, including the Form 8-A12B filed on June 27 2017 related to
the listing of
the Notes on the NYSE, Form 8-K12B filed July 7, 2017 disclosure that
the Notes are
listed on the NYSE, which was subsequently changed to the Nasdaq as
indicated in the
Certification filed December 6, 2021, and the cover page for previous
Forms 10-K and
10-Q of Baker Hughes Holdings LLC disclosing that the Notes were
registered on the
Nasdaq.
Please contact Joyce Sweeney at 202-551-3449 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Fernando Contreras