SEC Comment Letter for DIAMOND OFFSHORE DRILLING, INC. (DO, DODRW) (CIK 0000949039) — Sep 15, 2021
DIAMOND OFFSHORE DRILLING, INC. (DO, DODRW) (CIK 0000949039)
Date: Sept. 15, 2021 · CIK: 0000949039 · Accession: 0000000000-21-011190
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File numbers found in text: 333-257281
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United States securities and exchange commission logo
September 15, 2021
Bernie G. Wolford, Jr.
President and Chief Executive Officer
DIAMOND OFFSHORE DRILLING, INC.
15415 Katy Freeway, Suite 100
Houston, TX 77094
Re:DIAMOND OFFSHORE DRILLING, INC.
Amendment No. 1 to Registration Statement on Form S-1
Filed August 27, 2021
File No. 333-257281
Dear Mr. Wolford:
We have reviewed your amended registration statement 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 by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our July 8, 2021 letter.
Amendment No. 1 to Registration Statement on Form S-1
General
1.We note your response to prior comment 1, and re-issue such comment. In that regard, we
note your disclosure that there is currently no established public trading market for the
shares, and that you do not currently intend to apply for a listing of the shares on a
national securities exchange, quotation system or other recognized trading system. Please
revise your prospectus cover page, and elsewhere as appropriate, to disclose a fixed price
or bona fide price range at which the shares of your common stock will be sold by the
selling stockholders. Refer to Instruction 2 to Item 501(b)(3) of Regulation S-K.
FirstName LastNameBernie G. Wolford, Jr.
Comapany NameDIAMOND OFFSHORE DRILLING, INC.
September 15, 2021 Page 2
FirstName LastName
Bernie G. Wolford, Jr.
DIAMOND OFFSHORE DRILLING, INC.
September 15, 2021
Page 2
Please contact Liz Packebusch, Staff Attorney, at (202) 551-8749 or Laura Nicholson,
Special Counsel, at (202) 551-3584 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Shelton Vaughan