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VIA FACSIMILE (202) 942-1988 and EDGAR

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W., Mail Stop 3561

Washington, D.C. 20549-0305

Attention: Anthony Watson, Staff Accountant

    Re:

    MarineMax, Inc. (the “Company”)

    Form 10-K for the fiscal year ended September 30, 2007

    Filed: December 11, 2007

    DEF 14A filed January 16, 2008

    Form 8-K filed January 17, 2008

    From 8-K filed February 8, 2008

    Form 10-Q for the quarter ended December 31, 2007

    Filed: February 11, 2008

    Form 8-K filed March 5, 2008

    Form 8-K filed March 12, 2008

    File No. 1-14173

Ladies and Gentlemen:

     We are responding to comments on the Company’s above-referenced filings under the Securities
Act of 1934, as amended, provided by the staff (the “Staff”) of the Securities and Exchange
Commission by letter dated April 4, 2008. The Company’s responses to the Staff’s comments are
indicated below, directly following a restatement of each comment in bold, italicized type.

SEC Comment

Signatures, page 54

    1.

    We note your Form 10-K makes provision for your chief executive officer, your principal
financial officer and your controller or principal accounting officer and a majority of your
board to sign in their capacities on your behalf, however the filing has not been signed.
Please revise. See Form 10-K and general Instruction D(2)(a).

Company response:

    The Form 10-K was manually signed by our Chief Executive Officer, the Principal Accounting
and Financial Officer and all members of the Board of Directors. In the Edgarization
process the conformed signatures did not convert properly. We will revise accordingly.

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

 Item 9A. Controls and Procedures

 Item 11. Executive Compensation

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SEC Comment

    Item 7.

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

    2.

    Please expand this section to discuss known material trends and uncertainties that will have,
or are reasonably like to have, a material impact on your revenues or income or result in your
liquidity decreasing in any material way. Also, please provide additional information about
the quality and variability of your earnings and cash flows so that investors can ascertain
the likelihood of the extent past performance is indicative of future performance. Further,
discuss in reasonable detail economic or industry-wide factors relevant to your business and
material opportunities, challenges, and risks in the short and long term and the actions you
are taking to address them. Refer to Item 303 of the 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.

Company response:

    We propose to add the following paragraph to Item 7 — Management’s Discussion and Analysis
of Financial Condition and Results of Operations, sub-caption “Overview” to outline the
current state of the company and industry.

Fiscal 2007 was a challenging year for the marine industry, with a
reported double digit drop in retail unit sales. The economic softness has made it
more difficult for us to maintain the profitability that we desire, however we have
capitalized on our strengths to substantially outperform the industry and deliver
significant market share gains through an increase in unit sales. We believe the
investments we have made to grow market share will yield an increase in future
revenue as our customer’s trade into larger products. Our ability to deliver unit
sales results, that are far greater than the industry, supports the alignment of our
retailing strategies matching the desires of consumers. The cyclical nature of the recreational boating
industry has adversely affected our business and results of operations in Fiscal
2007. As general economic trends improve, we expect our financial strength and
retailing strategies position us to capitalize on growth opportunities as they occur
and will allow us to emerge from this challenging environment with greater earnings
potential.

Current economic conditions in areas in which we operate dealerships, particularly Florida and California, had a negative impact on our operations. General
economic conditions, sonsumer spending patterns, federal tax policies, interest rate levels, and the cost and
availability of fuel can impact overall boat purchases and as a result may materially impact our revenues and cash flows.
The uncertainty associated with these adverse economic and industry factors will continue to impact the variability in our operating results from what we have historically experienced.

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SEC Comment

    3.

    Disclose in a separately captioned section any off-balance sheet arrangements that have or
are reasonably likely to have a current or future effect on your financial condition. Your
discussion should include all of the information that is required by Item 303(a)(4) of
Regulation S-K. If there are none, please state that in your future filings.

Company response:

    We do not have any off-balance sheet arrangements. We do not see where a negative
affirmation is required by Item 303(a)(4). Please advise if the negative affirmation is a
preferred disclosure by the staff or required disclosure.

SEC Comment

Contractual Commitments and Commercial Commitments, page 48

    4.

    Please disclose scheduled interest payments under your long-term debt agreements in the table
or in a footnote to the table. Given that the interest rates under the majority of your
long-term debt agreements are variable, you should disclose the basis for your computation of
estimated interest payments. Please also include obligations related to other long-term
liabilities reflected in your balance sheet or disclose pertinent data for an understanding of
the timing and amount of such obligations. In addition, please disclose that lease
obligations exclude insurance, taxes, maintenance and other costs and provide a context for
readers to understand the impact of such costs on the obligations. 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.

Company response:

    We propose modifying the Contractual Commitments and Commercial Commitments table as
follows:

Contractual Commitments and Commercial Commitments

     The following table sets forth a summary of our material contractual obligations and
commercial commitments as of September 30, 2007:

    Short-Term

    Other Long-

    Borrowings

    Term

    Long-Term

    Operating

    Year Ending September 30,

    (1)

    Liabilities (2)

    Debt (1)

    Leases (3)

    Total

    (Amounts in thousands)

    2008

    $
    326,000

    $
    —

    $
    4,396

    $
    9,425

    $
    339,821

    2009

    —

    2,368

    4,474

    7,703

    14,545

    2010

    —

    —

    4,563

    7,071

    11,634

    2011

    —

    —

    3,902

    6,577

    10,479

    2012

    —

    —

    3,705

    5,375

    9,080

    Thereafter

    —

    —

    9,793

    16,615

    26,408

    Total

    $
    326,000

    $
    2,368

    $
    30,833

    $
    52,766

    $
    411,967

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    (1)

    Estimates of future interest payments for Short-Term Borrowings and Long-Term Debt
have been excluded in the tabular presentation. See Notes to Consolidated Financial
Statements for the fixed and variable interest rates related to each of the borrowings.

    (2)

    The amounts included in other long-term liabilities primarily consist of our estimated
liability for claims on certain workers’ compensation insurance policies. While we estimate
the amount to be paid in excess of 12 months, the ultimate timing of the payments is
subject to certain variability. Accordingly, we have classified all amounts as due in the
following year for the purposes of this table.

    (3)

    Amounts for operating lease commitments do not include certain operating expenses such
as maintenance, insurance, and real estate taxes. These amounts are not a material
component of operating expenses.

SEC Comment

Item 9A. Controls and Procedures, page 49

    5.

    You state that your chief executive officer and chief financial officer concluded that your
disclosure controls and procedures are effective to ensure that you record, process, summarize
and report information required to be disclosed in quarterly reports filed under the
Securities Exchange Act within the time periods specified in the Commission’s rules and forms.
Please revise to remove the quarterly qualification regarding quarterly reports as
disclosure controls and procedures apply to all reports filed or submitted under the
Securities Exchange Act. Also, revise to state, if true, that your chief executive officer
and chief financial officer concluded that your disclosure controls 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 disclosure controls and procedures in Exchange Act Rules 13a-15(e) and
15d-15(e). Additionally, please confirm to us your officers’ conclusion regarding the
effectiveness of your disclosure controls and procedures as defined in Exchange Act Rules
13a-15(e) and 15d-15(e).

Company response:

    We will revise the filing accordingly, removing the quarterly qualification. We also
confirm that our officers have concluded regarding the effectiveness of our disclosure
controls and procedures as defined in the Exchange Act Rules 13a-15(e) and 15d-15(e). We
will modify the disclosure to read as follows:

    Evaluation of Disclosure Controls and Procedures

We carried out an evaluation as required by Rules 13a-15(e) and 15d-15(e) under the
Securities Exchange Act of 1934, with the participation of our Chief Executive
Officer (CEO) and Chief Financial Officer (CFO), of the effectiveness of our
disclosure controls and procedures as of September 30, 2007. Based on this
evaluation, our CEO and CFO have each concluded that our disclosure controls and
procedures are effective to ensure that we record, process, summarize, and report
information required to be disclosed by us in our reports filed under the Securities
Exchange Act within the time periods specified by the Securities and Exchange
Commission’s rules and forms.

    Changes in Internal Controls

During our fourth quarter ended September 30, 2007, there were no changes in our
internal controls over financial reporting that materially affected, or were
reasonably likely to materially affect, our internal control over financial
reporting.

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SEC Comment

    6.

    Please revise your disclosure regarding changes in internal control over financial reporting
to identify any change in your internal control over financial reporting that occurred during
your last fiscal quarter that has materially affected, or is reasonably likely to materially
affect, your internal control over financial reporting. Refer to Item 308(c) of Regulation
S-K.

Company Response

    We will revise the disclosure accordingly. The proposed modification has been also been
incorporated into our response to comment #5.

SEC Comment

Item 11. Executive Compensation, page 11

Compensation Discussion and Analysis, page 6

    7.

    In future filings, clarify whether your President and Chief Executive Officer met with
representatives of Sibson Consulting regarding his compensation or the compensation of other
named executive officers and identify the members of management with whom Sibson Consulting
works.

Company Response

    In future filings we will clarify which members of management directly worked with Sibson
Consulting.

SEC Comment

Incentive Compensation, page 8

    8.

    We note that the bonuses for your named executives are based on a percentage of your
consolidated monthly pretax profit and upon the achievement of equally weighted goals. You
have not provided quantitative disclosure of the pre-determine goals that the compensation
committee established for the executive incentive compensation plan. In future filings,
please disclose or, to the extent you believe disclosure of these targets is not required
because it would result in competitive harm, provide us on a supplemental basis a detailed
explanation under Instruction 4 to Item 402(b) of Regulation S-K for this conclusion. See
also Question 3.04 of the Item 402 of Regulation S-K Interpretations available on our website
at www.sec.gov. If disclosure of the factors could cause competitive harm, please discuss
further how difficult it will be for the named executive officer or how likely it will be for
you to achieve the target levels or other factors. Please see Instruction 4 to Item 402(b) of
Regulation S-K.

Company Response

    In future filings we will include additional language disclosing the quantitative criteria
for achieving the goals unless they would cause competitive harm.

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SEC Comment

    9.

    Please discuss the extent to which the compensation committee can exercise or has exercised
discretion either to award compensation absent attainment of the relevant performance goals or
to reduce or increase the size of any award or payout. See Item 402(b)(2)(vi) of Regulation
S-K.

Company Response

    The compensation committee can exercise discretion in the execution of the compensation
plan. A discretionary bonus was paid to one of our executive officers and was disclosed on
page 10 of our Proxy Statement.

SEC Comment

Employment Agreements , page 19

    10.

    Please describe and explain how you determine the appropriate payment and benefit levels
under the various circumstances that trigger payments or provision of benefits upon
termination or a change in control in future filings. See Item 402(b)(1)(v) and 402(j)(3) of
Regulation S-K. Please discuss why you have chosen to pay certain multiples of the components
of compensation under these arrangements and how potential payments and benefits under these
arrangements may have influences the compensation committee’s decision regarding other
compensation elements.

Company Response

    We have determined to pay a multiple of base salary and bonus for designated time periods.
In determining the amounts, we considered similar provisions under employment agreements for
comparable positions in comparable companies. We believe the circumstances in which such
amounts are payable are clear and easily calculated.

SEC Comment

    11.

    While the Commission has not mandated tabular disclosure of potential post-employment
payments, we encourage you to present this information in future filings in a tabular format
so that investors may assess clearly the amount of compensation to be received under the
various scenarios that would lead to a named executive officer’s termination or change in
control of the company. See section VI of the Securities Act Release 33-8732A.

Company Response

    We will take this into consideration in preparing future filings.

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SEC Comment

Certain Transactions, page 19

    12.

    In future filings, please describe your policies and procedures for the review, approval, or
ratification of the transactions you describe this section. See Item 404(b) of Regulation
S-K.

Company Response

    In future filings we will disclose the additional information associated with these types of
transactions as requi