SecProbe.io

February 8, 2011
 Mitcham Industries, Inc. Robert P. Capps, Executive Vice Presiden t – Finance and Chief Financial Officer
8141 SH 75 South P.O. Box 1175
Huntsville, TX  33742

Re: Mitcham Industries, Inc.
 Form 10-K for the year ended January 31, 2010 filed April 9, 2010  Form 10-Q for the quarter ended October 31, 2010 filed December 8, 2010
File No. 0-25142

Dear Mr. Capps:
 We have reviewed your response to our letter dated January 19, 2011 and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 10-K for the year ended January 31, 2010

 Critical Accounting Policies

 Goodwill and Other Intangible Assets, page 34

1. We note your response to comment four of  our letter dated January 19, 2011.  You
indicate that you have identif ied your Seamap reportable segment as your reporting unit.
However, as noted on page one of your Form 10-K, your Seamap reportable segment is comprised of two operating segments, Seamap UK and Seamap Singapore.  As such, it is
unclear to us how you have appropriately iden tified your reporting uni ts pursuant to ASC
Topic 350-20-35.  Refer also to Topic 350-20- 35-33 through 35-46.  In this regard, we
note that a reporting unit is an operating segment or one level below an operating
segment (also known as a component).  Please reassess the appropriatene ss of the level at
which you assessed goodwill for impairment.

Mr. Robert P. Capps Mitcham Industries, Inc. February 8, 2011 Page 2

Notes to the Consolidated Financial Statements

 11. Income Taxes, page F-15

2. Please revise the disclosures you have proposed in response to prior comment five of our
letter dated January 19, 2011 to clarify that you have recorded a deferred tax asset related
to the Canadian net operating losses which ha s been offset your tax liability related to
uncertain tax positions.
 Form 10-Q for the quarter ended October 31, 2010

 Notes to the Condensed Conso lidated Financial Statements

 4. Acquisitions, page 4

3. Please include the information you have provi ded to us in response to prior comment
seven of our letter dated January 19, 2011 in your future disclosures.
 6. Balance Sheet, page 6

4. We have read your response to comment eight of our letter da ted January 19, 2011.
Please specifically tell us whether you perf ormed an impairment test of the assets you
were repossessing at October 31, 2010.  If not , please tell us why no such test was
necessary.  Please also tell us whether you ha ve recorded or will need to record any
additional impairment upon the repossession of those assets in December 2010.  If so,
please quantify the impairment charge and address why no such impairment was required
as of October 31, 2010.    Additionally, please provide to us your proposed disclosures for your Form 10-K for the year ended January 31, 2011.

You may contact Mindy Hooker at (202) 551-3732, Jeanne Baker at (202) 551-3691 or
me at (202) 551-3768 with any questions.
Sincerely,

John Cash Branch Chief