SecProbe.io

Mail Stop 3561           May 29, 2008   William H. McGill Jr. Chief Executive Officer MarineMax, Inc. 18167 U.S. Highway 19 North Suite 300 Clearwater, FL 33764

 Re:  MarineMax, Inc.   Form 10-K for the fiscal  year ended September 30, 2007
  Filed December 11, 2007   DEF 14A filed January 16, 2008   File No. 1-14173

Dear Mr. McGill:

We have reviewed your response letter dated May 2, 2008 and have the following
comments.  Where indicated, we think you should revise your document in response to these
comments. Otherwise, you should comply in all fu ture filings, as applicable.  Please confirm in
writing that you will do so and explain to us in sufficient detail for an understanding of the
disclosure how you intend to comply by providing us with your proposed revisions.  Please
confirm in writing that you will do so, and also explain to us how you intend to comply.  If you
disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary.  Please be  as detailed as necessary in your explanation.  After reviewing
this information, we may raise additional comments.
Form 10-K for Fiscal Year Ended September 30, 2007

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 41

Overview, page 41
1. We reviewed your response to comment two in our letter dated April 4, 2008 and the
proposed revisions to your disclosure.  Please consider providing forward-looking
information and quantifying the potential material effects of current economic conditions
on revenues, operating resu lts and cash flows.

William H. McGill Jr.
MarineMax, Inc. May 29, 2008 Page 2 of 3
2 Contractual Commitments and Commercial Commitments, page 48

2. We reviewed your response to comment four  in our letter dated April 4, 2008 and the
proposed revisions to your disclosure.  Pleas e quantify scheduled in terest payments under
your long-term debt agreements in footnote (1) to the table and disclo se the basis for your
computation of estimated interest payments.  Refer to Item 303(a)(5) of Regulation S-K
and Section IV.A and footnote 46 to the Commission’s Guidance Regarding
Management’s Discussion and Analysis of Financial Condition and Results of
Operations.
 Item 9A.  Controls a nd Procedures, page 49

3. We reviewed your response to comment five  in our letter dated April 4, 2008 and the
proposed revisions to your disclosure.  We re-issue our previous comment in part.  You state that your chief executive officer and chief financial officer concluded that your
disclosure controls and pro cedures are effective to ensu re that you record, process,
summarize and report information required to be disclosed in quarterly  reports filed under
the Securities Exchange Act within the tim e periods specified in the Commission’s rules
and forms.  Please revise to state, if true , that your chief executive officer and chief
financial officer also concl uded that your disclosure cont rols and procedures were
effective to ensure information required to be disclosed by you in the reports
 you file or
submit under the Securities Exchange Act is accumulated and communicated to management, including your chief executive and financial officers, to allow timely
decisions regarding required disclosures.  A lternatively, you could revise to simply state
that your chief executive officer and chief financial officer concluded disclosure controls and procedures are effective.
Item 11. Executive Compensation, page 11

 Compensation Discussion and Analysis, page 6

4. We note your response to prior comment eigh t in our letter dated April 4, 2008.  Please
provide us with the disclosure that you would expect to provide  in future filings regarding
the quantitative criteria.
 Employment Agreements, page 19

5. We note your response to prior comment 10 in  our letter dated April 4, 2008.  Please
confirm that you will provide your response to this comment in future filings.
 Certain Transactions, page 19

6. We note your response to prior comment 12 in  our letter dated April 4, 2008.  Please
provide us with the disclosure that you would expect to provide  in future filings regarding

William H. McGill Jr.
MarineMax, Inc. May 29, 2008 Page 3 of 3
3 the policies and procedures for the review, approval or rati fication of the transactions
described in this section.
 Notes to Consolidated Financial Statements, page F-8

7. We reviewed your response to comment 16 in our letter dated Apr il 4, 2008.  We believe
you should disclose revenues from external cu stomers for each group of similar products
and services for each  year presented pursuant to pa ragraph 37 of SFAS 131.  Please
revise or advise.

As appropriate, please amend your filings and respond to these comments within 10
business days or tell us when you will provide us with a response.  You may wish to provide us
with marked copies of the amendment to expedite  our review.  Please furn ish a cover letter with
your amendment that keys your responses to  our comments and pr ovides any requested
information.  Detailed cover lette rs greatly facilitate our review .  Please understand that we may
have additional comments afte r reviewing your amendment and responses to our comments.

Any accounting-related questions may be di rected to Anthony Watson, Staff Accountant
at (202) 551-3318 or William Thompson, Branch Chief at (202) 551-3344.  Questions on other disclosure issues may be directed to Mara L. Ransom, Branch Chief, at (202) 551-3264, or me at
(202) 551-3720 if you have any questions regarding your filing or this review.

Sincerely,

          H. Christopher Owings
Assistant Director