SEC Comment Letter for MIND TECHNOLOGY, INC (MIND) (CIK 0000926423) (MIND) — Dec 28, 2017

MIND TECHNOLOGY, INC (MIND) (CIK 0000926423)
Date: Dec. 28, 2017 · CIK: 0000926423 · Accession: 0000000000-17-045241

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AI Filing Summary & Sentiment

Date

December 22, 2017

Author

/s/ Pamela A. Long

Form

UPLOAD

Company

MIND TECHNOLOGY, INC (MIND) (CIK 0000926423)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4631 DIVISION OF CORPORATION FINANCE Mail Stop 4631 December 27 , 2017 Via E-Mail Mr. Robert P. Capps Co-Chief Executive Officer and Chief Financial Officer Mitcham Industries, Inc. 8141 AH 75 South P.O. Box 1175 Huntsville, TX 77340

Re: Mitcham Industries, Inc. Registration Statement on Form S -3 Filed December 22, 2017 File No. 333 -222278

Dear Mr. Capps :

This is to advise you that we have not reviewed and will not review your registration statement .

Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action, or absen ce of act ion by the staff.

You may contact Edward M. Kelly, Senior Counsel, at (202) 551 -3728 with any questions .

Very truly yours,
/s/ Pamela A. Long

Show Raw Text

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
       DIVISION OF
CORPORATION FINANCE

 Mail Stop 4631

       December 27 , 2017

Via E-Mail
Mr. Robert P. Capps
Co-Chief Executive Officer and Chief Financial Officer
Mitcham Industries, Inc.
8141 AH 75 South
P.O. Box  1175
Huntsville, TX 77340

 Re: Mitcham Industries, Inc.
  Registration Statement on Form S -3
  Filed December 22, 2017
  File No. 333 -222278

Dear Mr. Capps :

This is to advise you that we have not reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action, or absen ce of act ion by the staff.

 You may contact  Edward M. Kelly, Senior  Counsel,  at (202) 551 -3728  with any
questions .

       Very truly yours,

       /s/ Pamela A. Long

       Pamela A. Long
       Assistant Director
       Office of Manufacturing and Construction

cc: Via E-Mail

Mr. Robert P. Capps
Mitcham Industries, Inc.
December 27 , 2017
Page 2

  Gillian A. Hobson, Esq.
 Vinson & Elkins L.L.P.
 1001 Fannin Street, Suite 2500
 Houston, TX 77002

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