March 18, 2026

Rodney C. Reed
Senior Vice President and Chief Financial Officer
NOV Inc.
10353 Richmond Avenue
Houston, Texas 77042-4103

       Re: NOV Inc.
           Form 10-K for the Fiscal Year ended December 31, 2025
           Filed February 12, 2026
           File No. 001-12317
Dear Rodney C. Reed:

       We have reviewed your filing 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 for the Fiscal Year ended December 31, 2025
Financial Statements
Note 16 - Business Segments and Geographic Areas, page 81

1.     We note that you include two tables on page 83 having various segment
details,
       including one with "Pre-tax Other Items," which are described in
footnote (2) to the other
       table and included in various line items of the other table. Please
modify your disclosures
       as necessary to clarify which line items within the other table
represent the significant
       expense categories and amounts that are regularly provided to your CODM,
which you
       are disclosing pursuant to FASB ASC 280-10-50-26A.

       Please explain to us how you considered the distinction made by the FASB
in
       establishing the disclosure requirements for significant expense
categories in FASB ASC
       280-10-50-26A, and the disclosure requirements for the amount of other
segment items
       (representing the difference between segment revenues, less the amounts
in the
       significant expense categories, and the segment measures of profit or
loss) in FASB ASC
       280-10-50-26B, and the reasons this is not apparent in your current
presentation.
 March 18, 2026
Page 2

       Please also explain to us how you adhered to the requirements in FASB
ASC 280-10-50-
       26A, to "...consider relevant qualitative and quantitative factors when
determining
       whether segment expense categories and amounts are significant" for
purposes of these
       disclosures, and how your evaluation has encompassed not only the
segment expenses
       that are regularly provided to the CODM, but also segment expenses that
are "easily
       computable from information that is regularly provided" to the CODM.

       On a related point, please clarify whether the CODM is regularly
provided information
       regarding the cost of revenue for the categories of products, services,
and rentals, as
       utilized in the presentation on page 53, and if so indicate how these
categories were
       determined to be other than significant expense categories, if this is
your view.

2.     We note that you have limited disclosures pertaining to revenues under
this heading to
       revenue from external customers and intersegment revenues based on FASB
ASC 280-
       10-50-22, and revenues by four geographical areas based on FASB ASC
280-10-50-41.
       We also note that you report revenues on page 76 for the categories of
services and
       rentals, sales of shorter-lived capital equipment, sales of consumable
products, sales of
       long-lived capital equipment, and aftermarket sales and services.

       However, on page 3 you indicate that you manufacture a diverse line of
products and on
       pages 4 through 6, you identify about 17 product and service offerings
in describing your
       reportable operating segments. Please expand your disclosures under this
heading as
       necessary to address the requirement in FASB ASC 280-10-50-40, to report
revenues
       for each product and service, or each group of similar products and
services.

       If you believe that revenues for some categories of products and
services should be
       combined because they are similar, or if believe that providing the
information is
       impracticable, provide us with details of your assessments in this
regard.


        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 Gus Rodriguez at 202-551-3752 or John Cannarella at
202-551-3337 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Energy &
Transportation