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OCCIDENTAL PETROLEUM CORPORATION |
10889 WILSHIRE BOULEVARD TELEPHONE (310) 208-8800 FACSIMILE (310) 443-6690 |
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STEPHEN I. CHAZEN |
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PRESIDENT |
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AND |
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CHIEF FINANCIAL OFFICER |
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Direct Telephone |
(310) 443-6311 |
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Direct Facsimile |
(310) 443-6812 |
July 13, 2010
Via Facsimile and U.S. Mail
United States Securities and Exchange Commission
100 F Street N.E., Stop 7010
Washington, D.C. 20549
Attention: Mr. H. Roger Schwall
Assistant Director
Division of Corporation Finance
Re: Occidental Petroleum Corporation
Form 10-K for Fiscal Year Ended December 31, 2009
Filed February 25, 2010
Schedule 14A filed March 23, 2010
Response Letter Dated May 7, 2010
Response Letter Dated June 14, 2010
File No. 001-9210
Dear Mr. Schwall:
The information set forth below is submitted in response to your comments on the referenced filings, as set forth in your July 9, 2010 letter. Capitalized terms used in this letter and not otherwise defined have the meanings ascribed to them in the 2009 Form 10-K. The numbered paragraph and headings correspond to the numbered paragraph and headings of your letter.
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Occidental Response to SEC Letter |
July 13, 2010 |
Form 10-K for the Fiscal Year ended December 31, 2009
Supplemental Oil and Gas Information (Unaudited), page 71
1. We note your response to prior comment five. Please confirm that you will include in your tables amounts related to your non-controlling interests in consolidated subsidiaries in future filings, as contemplated by ASC 932-235-50-8(a).
Response to Comment 1
We confirm that we will include in our tables amounts related to our non-controlling interests in consolidated subsidiaries in our future Annual and Quarterly Reports.
Occidental acknowledges that:
· Occidental is responsible for the adequacy and accuracy of the disclosure in the referenced filings;
· Staff comments or changes to disclosure in response to staff comments do not foreclose the SEC from taking any action with respect to the referenced filings; and
· Occidental may not assert staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.
If you need any further information or elaboration, or if you wish to discuss any of the information presented above, please call me at your convenience at (310) 443-6311.
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Very truly yours, |
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/s/ Stephen I. Chazen |
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Stephen I. Chazen |
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President and |
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Chief Financial Officer |