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CORRESP Filing

ODYSSEY MARINE EXPLORATION INC
Date: April 16, 2025 · CIK: 0000798528 · Accession: 0001193125-25-082808

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File numbers found in text: 333-286323

Date
April 16, 2025
Author
O DYSSEY M ARINE E XPLORATION , I NC .
Form
CORRESP
Company
ODYSSEY MARINE EXPLORATION INC

Letter

Re: Odyssey Marine Exploration, Inc. Registration Statement on Form S-3 SEC Registration No.: 333-286323 Ladies and Gentlemen: On behalf of Odyssey Marine Exploration, Inc. (the “ Company ”) and pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests acceleration of the effectiveness of the above-referenced Registration Statement on Form S-3 so that it will become effective at 4:30 p.m., Eastern Time, on Monday, April 21, 2025, or as soon as practicable thereafter. In connection with the foregoing, the Company hereby acknowledges that:

O DYSSEY M ARINE E XPLORATION , I NC . 205 S. Hoover Boulevard Suite 210 Tampa, Florida 33609 April 16, 2025 VIA EDGAR Securities and Exchange Commission Division of Corporate Finance Office of Energy & Transportation 100 F Street N.E. Washington, D.C. 20549

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please confirm the date and time of effectiveness of the registration statement to David M. Doney at Akerman LLP, our counsel, at (813) 209-5070.

Very truly yours,
O DYSSEY M ARINE E XPLORATION , I NC .

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CORRESP
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 CORRESP

 O DYSSEY M ARINE E XPLORATION ,
I NC . 205 S. Hoover Boulevard
 Suite 210 Tampa, Florida
33609 April 16, 2025 VIA EDGAR
 Securities and Exchange Commission Division of
Corporate Finance Office of Energy & Transportation
 100 F Street N.E. Washington, D.C. 20549

 Re:
 Odyssey Marine Exploration, Inc.
 Registration Statement on Form S-3
 SEC Registration No.: 333-286323
 Ladies and Gentlemen: On behalf of Odyssey
Marine Exploration, Inc. (the “ Company ”) and pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests acceleration of the effectiveness of the above-referenced Registration Statement
on Form S-3 so that it will become effective at 4:30 p.m., Eastern Time, on Monday, April 21, 2025, or as soon as practicable thereafter. In connection with the foregoing, the Company hereby acknowledges
that:

 •

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does
not foreclose the Commission from taking any action with respect to the filing;

 •

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing
effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 •

 the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the United States. Please confirm the
date and time of effectiveness of the registration statement to David M. Doney at Akerman LLP, our counsel, at (813) 209-5070.

 Very truly yours,

 O DYSSEY M ARINE E XPLORATION , I NC .

 /s/ Mark D. Gordon

 Mark D. Gordon

 Chief Executive Officer