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LETTER TO MR. SCHWALL

[LINKLATERS LETTERHEAD]

    Avocats à la Cour de Paris

Solicitors of the Supreme Court of England and Wales

    25 rue de Marignan

75008 Paris

Telephone +33 1 56 43 56 43

Facsimile +33 1 43 59 41 96

Palais J 030

Direct Line +33 1 56 43 58 82

H. Roger Schwall

Assistant Director

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

United States of America

September 19, 2005

Our Ref          L-096813

Dear Mr. Schwall,

General Geophysics Company Registration Statement on Forms F-4 and S-4 Filed on July 13, 2005
(File No. 333-126556) and Annual Report on Form 20-F for the year ended December 31, 2004 Filed
April 18, 2005 (File No. 01-14622)

We refer to the Staff’s comment letters dated August 11, 2005 and September 8, 2005 on the
above-referenced Registration Statement on Forms F-4 and S-4 (the “Registration Statement”) and the
above-referenced Annual Report on Form 20-F (the “Annual Report”) of General Geophysics Company
(the “Company”).

Set forth below in detail are the Company’s responses to the Staff’s comments. For your
convenience, each comment is repeated below, prior to the response. The Company will submit for
filing with the Securities and Exchange Commission (the “Commission”) an amended Annual Report on
Form 20-F/A (the “Amended Annual Report”) and an Amendment No. 1 to the Registration Statement on
Forms F-4 and S-4 incorporating by reference the Amended Annual Report after it has fully addressed
all of the Staff’s comments. For your information, the text of the proposed disclosure in the
Amended Annual Report, marked to show changes against the Annual Report as currently filed, is
attached in Annex A and Annex B.

Responses to September 8, 2005 Comment letter

Forms F-4 and S-4 and Form 20-F for the Year Ended December 31, 2004

Operating and Financial Review and Prospects, page 29

Liquidity and Capital Resources, page 39

    1.

    We have read your response to prior comment 2, explaining that you wish to present your
non-GAAP measure of Operating Results Before Depreciation and Amortization because it
represents a factor necessary to calculate a ratio identified as a debt covenant item. Given
this representation, it is unclear why you have not also shown the ratio that you believe is
of such importance, and included discussion of the extent of your compliance with the
covenant.

A list of the names of the partners and their professional qualifications is open to inspection at the above office.
The partners are solicitors, registered foreign lawyers or registered European lawyers.

Please refer to www.linklaters.com/regulation for important information on the regulatory position of the firm.

Response

In response to the Staff’s comment, the Company intends to revise its disclosure on ORBDA by
setting out the required ratios under the Company’s syndicated credit facility and its actual
ratios for historical periods. The additional disclosure is marked in Annex A.

Financial Statements

Note I — Summary of Significant Accounting Policies, page F-7

Multi-Client Survey Accounting, page F-8

Revenue Recognition

    2.

    We note your response to prior comment 5, in which you explain that you “must reconsider the
final payment to be received from the customer if certain milestones are not met,” while
further clarifying in your draft disclosure revision, that under such circumstances, “...the
Company reduces its revenues accordingly.” For U.S. GAAP purposes, the guidance in SAB Topic
13:A, paragraphs 3(b) and 4(a), imposes limitations on revenue recognition when customer
acceptance has not been received, or when the sales price is not fixed or determinable, as is
generally believed to be the case during periods in which the customer has a right to cancel
the transaction and receive a cash refund. This guidance further explains that “...revenue
should not be recognized in earnings by assessing the probability that significant but
unfulfilled terms of a contract will be fulfilled at some point in the future.”

    Please elaborate on the meaning of your phrases “must reconsider” and “may be bound to
reconsider,” as they relate to circumstances in which milestones are established by
contractual arrangement; and describe the manner by which you would reduce your revenues to
comply with your contractual obligations, governing the provision of services. Tell us why
you believe the guidance in SAB Topic 13 would not require the deferral of revenue
recognition on contracts including customer acceptance provisions, or extending a right of
cancellation to customers, until acceptance has occurred or the rights of cancellation have
lapsed, for U.S. GAAP purposes, if that is your view.

Response

The Company regrets that its wording was not clear with respect to this issue. By the phrase
“reduces its revenues”, the Company meant that the amount of revenue initially recognized is
reduced, not that revenues are recognized fully and then subsequently reduced. By the phrases “must
reconsider” and “may be bound to reconsider”, the Company meant that it defers the recognition of
final payment if certain contractual milestones are not met. The Company proposes to use the
following wording in place of the last paragraph in Annex B:

“In some exclusive survey contracts and a limited number of multi-client survey contracts, the
Company is required to meet certain milestones. The Company defers recognition of revenue on such
contracts until all milestones that provide the customer a right of cancellation or refund of
amounts paid have been met.”

Responses to August 11, 2005 Comment letter

Forms F-4 and S-4 and Form 20-F for the Year Ended December 31, 2004

General

    3.

    Please note that our staff continues to review the company’s no-action request. We may have
further comment.

Based on the Staff’s telephone conversation with Linklaters on August 18, 2005, the Company
understands that the request for “no action” relief will not be granted because it is the Staff’s
view that the Company may rely on the relevant provisions of Rule 3-10 under Regulation S-X of the
Securities Act of 1933 (and the adopting release relating thereto) without availing itself of such
relief.

Operating and Financial Review and Prospects, page 29

Liquidity and Capital Resources, page 39

    4.

    We note that you have presented the non-GAAP measure “Operating Results Before Depreciation
and Amortization.” Given that you have characterized this measure as being indicative of your
operating cash flow and ability to meet debt service and capital expenditure requirements, the
guidance in Item 10(e)(1)(i)(B) of Regulation S-K would tend to require that you reconcile the
measure to operating cash flow rather than operating income. Please revise your filing
accordingly. Please also ensure that you have met the requirements outlined in paragraph
(1)(ii)(A) of this guidance, regarding adjustments to non-GAAP liquidity measures in
Commission filings.

Response

In response to the Staff’s comment, the Company will replace the reconciliation of “Operating
Results Before Depreciation and Amortization” (“ORBDA”) appearing in Item 5, page 41 of the Annual
Report with the reconciliation of ORBDA to Net cash provided by operating activities, as presented
in the consolidated statements of cash-flows on page F-5 of the Annual Report. The replacement text
appears at Annex A to this Letter.

Regarding the requirements outlined in paragraph (1) (ii) (A) of Item 10(e) of Regulation S-K, we
refer to Question 10 of the Staff’s “Frequently Asked Questions Regarding the Use of Non-GAAP
Financial Measures” dated June 13, 2003. The Staff answered that question by stating that
information about a material term of an agreement that is material to a company’s financial
condition and/or liquidity may require disclosure about the measure if it is material to an
understanding of the company’s financial condition and liquidity, even if it is otherwise
prohibited by Item 10(e) of Regulation S-K.

The Company’s U.S.$60 million syndicated credit facility dated March 12, 2004 described on page 41
of the Annual Report contains a financial covenant providing a maximum level of 2:1 for the
Company’s ratio of consolidated net debt to ORBDA. The Company believes that this covenant is a
material term of a material agreement. In light of this belief, the Company intends to replace the
paragraph on pages 40-41 of the Annual Report introducing ORBDA with the introductory paragraph
appearing at Annex A to this Letter.

The purpose of disclosing ORBDA as a liquidity measure is to provide a comparable measure of
liquidity from one period to another by excluding the effect of specific events not likely to recur
within two years. The Company understands that this measure is used by certain investors to
determine its operating cash-flow and historical ability to meet debt service and capital
expenditure requirements.

Financial Statements

Note I — Summary of Significant Accounting Policies, page F-7

Multi-Client Survey Accounting, page F-8

Revenue Recognition

    5.

    We note your disclosure stating that “[w]ithin thirty days of execution and access, the
client may exercise the Company’s warranty that all the data conforms to technical
specifications.” Please expand your disclosure to further clarify whether this provision
constitutes a right-of-return. If this is the case, please also explain how this contingency
has factored into the timing of revenue recognition.

Response

In the Company’s multi-client activity, clients see the seismic data they intend to use before
signing non-exclusive license agreements and accept the data on an “as is” basis. The Company
provides the seismic data on magnetic cartridges that are sometimes subject to technical
malfunctions in the copying of data. The Company provides a warranty of technical conformity only.
As a result, this provision is not a right-of-return of the data since the client can only request
the replacement of the magnetic cartridge if the cartridge it originally received does not
function. This clause is common in the Company’s industry and is not comparable to a cancellation
clause. This contingency is not factored into the timing of the Company’s revenue recognition, as
it does not constitute a right of return. The cost of providing new magnetic cartridges is
negligible.

The Company intends to revise its disclosure as set forth in the fourth paragraph of “Multi-client
survey accounting” in the attached Annex B.

    6.

    We note that the nature of your business requires the movement of people and equipment to a
designated location. Please disclose your accounting policy pertaining to payments that you
receive during periods of mobilization.

Response

The Company recognizes payments that it receives during periods of mobilization as advance billing
and these payments appear in the balance sheet in the item “Advance billings to customers”. The
Company recognizes revenues when production is begun, consistent with the technical progress of the
project.

The Company intends to revise its disclosure as set forth in the second paragraph of “Multi-client
survey accounting” in the attached Annex B.

    7.

    Please describe any contractual provisions associated with surveys in process establishing
target dates for progress or completion, and extending rights to customers for a return of
funds if milestones such as these are not met. Also describe any contractual provisions
requiring you to share future revenues with pre-commitment or other customers. Disclose the
manner by which you have factored any such arrangements into your recognition policy.

Response

In some exclusive survey contracts and a limited number of multi-client survey contracts, the
Company must reconsider the final payment to be received from the customer if certain milestones
are not met.

When the Company becomes aware that contractual targets cannot be reached, the Company reduces its
revenues.

The Company is not a party to any contractual provisions requiring it to share future revenues with
pre-commitment or other clients.

The Company intends to revise its disclosure as set forth in the second paragraph of “Exclusive
survey accounting” in the attached Annex B.

* * * * *

Should the Staff have any questions or require any additional information, please telephone Thomas
N. O’Neill III (tel: +331 5643 5882) or Luis Roth (tel: +331 5643 5842). For your convenience, our
e-mail addresses are tom.oneill@linklaters.com and luis.roth@linklaters.com, respectively.

Yours sincerely

Thomas N. O’Neill III/Luis Roth

    cc :

    Jason Wynn, Securities and Exchange Commission

John Weitzel, Securities and Exchange Commission

Karl Hiller, Securities and Exchange Commission

Michel Ponthus, Compagnie Générale de Géophysique

Beatrice Place-Faget, Compagnie Générale de Géophysique

Erwan Candau, Mazars & Guerard

Nicolas Pfeuty, Barbier Frinault & Autres, Ernst & Young

ANNEX A

“ORBDA” (Operating Result Before Depreciation and Amortization, previously denominated “Adjusted
EBITDA”) is defined as operating income (loss) excluding non-recurring revenues (expenses) plus
depreciation, amortization and additions (deductions) to valuation allowances of assets and
add-back of dividends received from equity companies. ORBDA is presented as additional information
because our syndicated credit facility dated March 12, 2004 requires us to respect a maximum ratio
of consolidated net debt to ORBDA. The maximum ratio of consolidated net debt to ORBDA was 2.00
to 1 for periods ending on or before December 31, 2004, compared to our actual ratio of 0.86 to 1
and 0.84 to 1 for the years ended December 31, 2003 and 2004, respectively. The maximum permitted
ratio is 1.75 to 1 for subsequent periods ending on or before December 31, 2005 (revised to 2.50 to
1 in a waiver dated August 31, 2005) and 1.50 to 1 thereafter. If we fail to meet this ratio
and do not obtain a waiver, we may be unable to borrow under the syndicated credit facility and may
be compelled to repay amounts outstanding under the facility. Either the inability to borrow or the
requirement to repay borrowed sums may have a negative effect on our liquidity and, consequently,
may increase our vulnerability to general adverse economic and industry trends or limit our
flexibility in adapting to such trends. ORBDA is not a measure of financial performance under
French GAAP, U.S. GAAP or IFRS and should not be considered as an alternative to cash flow from
operating activities or as a measure of liquidity or an alternative to net income as indicators of
our operating performance or any other measures of performance derived in accordance with French
GAAP, U.S. GAAP or IFRS.

The following table presents a reconciliation of “Operating Results Before Depreciation and
Amortization” (“ORBDA”) to Net cash provided by operating activities for the periods indicated as
follows:

    December 31,

    2004

    2003

    2002

    (in million of euros)

    ORBDA

    165.4

    162.3

    210.1

    Interests and other financial income and expense — net

    (22.4
    )

    (21.0
    )

    (32.6
    )

    Exchange gains — net

    4.4

    4.6

    7.9

    Income tax expense

    (9.7
    )

    (3.1
    )

    (17.4
    )

    Deferred income tax

    (12.7
    )

    (11.6
    )

    2.0

    Other non-cash items

    (7.7
    )

    (20.1
    )

    (19.0
    )

    Non-recurring gains (losses)

    0.1

    (7.8
    )

    69.1

    Less net gain on sale of asset

    (10.5
    )

    (6.0
    )

    (4.3
    )

    Dividends received from equity companies

    —

    (0.7
    )

    —

    Increase (decrease) in other long-term liabilities

    3.6

    (5.4
    )

    5.9

    (Increase) decrease in trade accounts and notes receivables

    (28.5
    )

    16.0

    60.5

    (Increase) decrease in inventories