SecProbe.io

Mail Stop 3561
July 17, 2008
 William H. McGill Jr.
Chief Executive Officer
MarineMax, Inc. 18167 U.S. Highway 19 North Clearwater, FL 33764
Re: MarineMax, Inc.
Form 10-K for Fiscal Year Ended September 30, 2007 Filed December 11, 2007 Definitive Proxy Statement filed on Schedule 14A Filed January 16, 2008 Written Response Filed June 26, 2008 File No. 1-14173
 Dear Mr. McGill:
 We have reviewed your response to our letter dated June 26, 2008 and have the
following additional comments.  In each of our comments below, please confirm in writing to us in detail sufficient for an understanding of your disclosure how you intend
to comply in future filings by furnishing us your proposed revisions.  After reviewing this
information, we may raise additional comments.  Compensation Discussion and Analysis, page 6

1. We note your response to prior comment four in our letter dated May 29, 2008.
We recognize that specific di sclosure of future events is not possible, but rather
what is requested is the general format  and tenor of your proposed disclosure
expanded from your prior year informati on.  We understand that your disclosure
will be tailored to the specifics at the time.  We also note you believe disclosure
of quantitative criteria would cause you competitive harm.  Please revise your disclosure to discuss how difficult it w ill be for named executive officers or how
likely it will be for you to achieve the quant itative criteria.  Pl ease see Instruction
4 to Item 402(b) of Regulation S-K a nd the questions in Section 118 of the
Compliance &.Disclosure Inte rpretations July 3, 2008 at
http://www.sec.gov/divisions/cor pfin/cfguidance.shtml#regs-k
.  Please provide us
with the disclosure you would expect to  present in future filings regarding
quantitative disclosure and the diffi culty of achieving the criteria.

William H. McGill Jr.
MarineMax, Inc. July 17, 2008 Page
2

Certain Transactions, page 19
2. We note your response to prior comment  six in our letter dated May 29, 2008.
You state in your proposed disclosure that your board of directors will review and
approve transactions with your directors or officers.  Please revise this discussion to provide additional information regarding your policies and procedures relating to the review and approval of such tran sactions, as required pursuant to Item
404(b) of Regulation S-K.  Specifically, indicate how you will determine whether
a board member or an officer has a “direc t or indirect financial interest” in the
transaction.  Please also i ndicate whether these policie s and procedures are in
writing.
*****

 As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Detailed cover letters gr eatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comments.
You may contact Scott Anderegg, Staff A ttorney, at (202) 551-3342, or me at
(202) 551-3720 with any questions.

Sincerely,
    H. Christopher Owings
Assistant Director