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Elizabeth A. Ising - SEC

January 30, 2017 Elizabeth A. Ising Gibson, Dunn & Crutcher LLP Re: occidental petroleum corporation Dear Ms. Ising : This is in regard to your letter dated January 27, 2017 concerning the shareholder proposal submitted by The Needmor Fund et al. for inclusion in occidental s proxy materials for its upcoming annual meeting of security holders. Your letter indicates that the proponents have withdrawn the proposal and that occidental therefore withdraws its January 5, 2017 request for a no-action letter from the Division. Because the matter is now moot, we will have no further comment.

Elizabeth A. Ising . Gibson, Dunn & Crutcher LLP . ... Finance concur that our client, Occidental Petroleum Corporation (the “Company”), could ... a dual investment mandate: competitive financial returns and positive social and environmental impact. Walden is an ...

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