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MITCHAM INDUSTRIES, INC.

P.O. Box 1175

HUNTSVILLE, TEXAS 77342-1175

June 1, 2011

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3561

Attention: Ms. Sherry Haywood

    Re:

    Mitcham Industries, Inc. (the “Registrant”)

Request for Acceleration of Effectiveness

Registration Statement on Form S-3 (File No. 333-172935)

(the “Registration Statement”)

Ladies and Gentlemen:

     Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of
1933, the Registrant hereby requests that the effectiveness of the above-captioned Registration
Statement be accelerated so that the Registration Statement will become effective June 3, 2011, at
3:00 p.m. Eastern time, or as soon thereafter as practicable.

     The Registrant hereby acknowledges that the disclosure in the Registration Statement is the
responsibility of the Registrant. The Registrant hereby further acknowledges that:

    •

    should the Securities and Exchange Commission (the “Commission”) or the
staff, acting pursuant to delegated authority, declare the Registration Statement
effective, it does not foreclose the Commission from taking any action with respect to
the Registration Statement;

    •

    the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not relieve the
Registrant from its full responsibility for the adequacy and accuracy of the disclosure
in the Registration Statement; and

    •

    the Registrant may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

     Should the Staff have any questions or comments, please call Gillian A. Hobson of Vinson &
Elkins L.L.P., the Registrant’s outside legal counsel, at (713) 758-3747 with any questions
regarding this request for acceleration.

    Sincerely,

MITCHAM INDUSTRIES, INC.

    By:
    /s/ Billy F. Mitcham, Jr.

    Name:
    Billy F. Mitcham, Jr.

    Title:
    President and Chief Executive Officer

    cc:

    Gillian A. Hobson, Esq.

Vinson & Elkins L.L.P.