United States securities and exchange commission logo June 9, 2020 Thomas P. McCaffrey President, Chief Executive Officer, and Chief Financial Officer KLX Energy Services Holdings, Inc. 1300 Corporate Center Way Wellington, Florida 33414 Re: KLX Energy Services Holdings, Inc. Registration Statement on Form S-4 Filed June 2, 2020 File No. 333-238870 Dear Mr. McCaffrey: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Valerie Ford Jacob, Esq.