SEC Company Response from ION GEOPHYSICAL CORP (CIK 0000866609) — Mar 10, 2021
ION GEOPHYSICAL CORP (CIK 0000866609)
Date: March 10, 2021 · CIK: 0000866609 · Accession: 0001104659-21-034354
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File numbers found in text: 333-252590
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CORRESP
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Oppenheimer & Co. Inc.
85 Broad Street
New York, NY 10004
March 10, 2021
VIA EDGAR
Tim Levenberg
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: ION Geophysical Corporation (CIK No. 0000866609)
GX Technology Corp (CIK No. 0001600867)
I/O MARINE SYSTEMS, INC. (CIK No. 0001600904)
ION EXPLORATION PRODUCTS (U.S.A.), INC. (CIK No. 0001600906)
GX Geoscience Corporation, S. de R.L. de C.V. (CIK No. 0001841419)
Registration Statement on Form S-1, as amended
Filed March 3, 2021
File No. 333-252590
Dear Mr. Levenberg:
Pursuant to Rule 461 under the Securities
Act of 1933, as amended (the “Securities Act”), the undersigned, Oppenheimer & Co. Inc., as dealer manager, hereby
joins in the request of ION Geophysical Corporation that the effectiveness of the above-referenced Registration Statement be accelerated
so as to permit it to become effective at 4:00 p.m. EDT on Wednesday, March 10, 2021 or as soon as thereafter practicable.
In making this request the undersigned
acknowledges that the dealer manager is aware of its obligations under the Securities Act as they relate to the public offering
of securities pursuant to the registration statement.
[Remainder of Page Intentionally Blank]
Sincerely,
OPPENHEIMER & CO. INC.,
as Dealer Manager
By:
/s/ John C. Fleming
Name: John C. Fleming
Title: Managing Director
cc: Gerald Spedale
Partner, Gibson, Dunn & Crutcher LLP
811 Main Street, Suite 3000
Houston, Texas 77002-6117