SecProbe.io

CORRESP
1
filename1.htm

corresp

December
23, 2005

Via EDGAR and

Facsimile (202) 772-9220

    Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549 - 7010

    Attn:  Jenifer Gallagher

    Karl Hiller

    Re.

    Superior Energy Services, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2004

Filed March 15, 2005

File No. 333-22603

Ladies and Gentlemen:

     This letter is being filed on behalf of Superior Energy Services, Inc. (the “Company”) in
response to the comment received from the Commission’s staff by facsimile transmission on December
15, 2005 with respect to the above-captioned Form 10-K. To expedite your review of the response
set forth below, we have numbered and reproduced in italics the full text of the staff’s comment
followed by the response.

General

    1.

    We note you filed a Form S-4 to register your 8.875% Senior Notes, due May 2011
in July 2001. In addition, we note you included within the Form S-4 condensed
consolidated financial information related to certain subsidiary guarantors of the
notes. Under Rules 3-10(f) and 3-10(i)(8) of Regulation S-X, you are required to also
include subsidiary guarantor financial information and related disclosures in the
periodic reports you are required to file under the Exchange Act. Please comply with
these reporting requirements, or tell us why you believe they are no longer applicable.

Response

     As noted, the Company previously included condensed consolidated financial information related
to certain subsidiary guarantors of the 8.875% senior notes within the Form S-4, which the Company
filed in July 2001. The Form S-4 registering the senior notes was declared effective on July 26,
2001 (Reg. No. 333-64946) and the related exchange offer was

Securities and Exchange Commission

December 23, 2005

Page 2 of 2

completed on August 27, 2001. Since the senior notes are held by a small number of
institutional investors, on September 19, 2001, we filed a Form 15 to terminate the registration of
the notes and, thereby, the requisite filing requirement under Rule 3-10 with respect to these
securities and our concomitant reporting obligations under the Exchange Act. Accordingly, we
haven’t viewed Rules 3-10(f) or (i) to be applicable to our senior notes or subsidiary guarantees
on an ongoing basis. However, as part of our Exchange Act reporting procedures, we did consider
voluntarily including condensed consolidated financial information. As part of this review, we
noted that the (i) the senior notes are held by a small number of sophisticated investors, (ii) the
assets and earnings of our non-guarantor subsidiaries are minimal and (iii) significant additional
cost would be incurred in order to provide this additional financial information. As a result, we
concluded that providing the subsidiary guarantor financial information would not be cost-effective
or contribute to an enhanced presentation of our financial position. Since we made this
determination, none of our note holders has questioned this determination or requested any
additional related financial information.

     Thank you for your assistance with this filing. If you have questions or comments, please
call me at your convenience at (504) 362-4321.

    Sincerely,

/s/
Robert S. Taylor

    Robert S. Taylor

    Executive Vice President, Treasurer and

Chief Financial Officer