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SEC Company Response from ION GEOPHYSICAL CORP (CIK 0000866609) — Mar 9, 2021

ION GEOPHYSICAL CORP (CIK 0000866609)
Date: March 9, 2021 · CIK: 0000866609 · Accession: 0001104659-21-033769

AI Filing Summary & Sentiment

File numbers found in text: 333-252591

Date
March 3, 2021
Author
/s/ Michael Morrison
Form
CORRESP
Company
ION GEOPHYSICAL CORP (CIK 0000866609)

Letter

VIA EDGAR Division of Corporation Finance Office of Trade & Services Division of Corporation Finance Re: ION Geophysical Corporation Registration Statement on Form S-4 Filed March 3, 2021 File No. 333-252591

Dear Mr. Levenberg:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, ION Geophysical Corporation (the “Registrant”) hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. EDT on Wednesday, March 10, 2021, or as soon as thereafter practicable.

Very truly yours,
/s/ Michael Morrison

Show Raw Text
CORRESP
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ION Geophysical Corporation

2105 CityWest Blvd., Suite 100

Houston, Texas 77042

March
9, 2021

VIA EDGAR

Tim Levenberg

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    ION Geophysical Corporation

    Registration Statement on Form S-4

    Filed March 3, 2021

    File No. 333-252591

Dear Mr. Levenberg:

Pursuant to Rule 461 under the Securities
Act of 1933, as amended, ION Geophysical Corporation (the “Registrant”) hereby requests acceleration of effectiveness
of the above referenced Registration Statement so that it will become effective at 4:00 p.m. EDT on Wednesday, March 10, 2021, or as
soon as thereafter practicable.

    Very truly yours,

    /s/ Michael Morrison

    Michael Morrison

    Executive Vice President and Chief Financial Officer

    cc:

        J. Eric Johnson

        Partner, Winston & Strawn LLP

        800 Capitol Street, Suite 2400

        Houston, Texas 77002