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VIA 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

    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

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 results and cash flows.

Company response:

In future filings, we will consider expanding forward-looking information about the impact
of the current economic conditions on revenue, operating results and cash flows to the
extent that we are able to reasonably quantify and project the impact of current trends on
future operations. At the time of the filing of the Form 10-K, we were not in a position to
increase our forward-looking disclosures due to the significance of the uncertainty in the
marketplace at that time.

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SEC Comment

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. Please quantify scheduled interest payments under
your long-term debt agreements in footnote (1) to the table and disclose 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.

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-

    Year Ending

    Borrowings

    Term

    Long-Term

    Operating

    September 30,

    (1)

    Liabilities (2)

    Debt (3)

    Leases (4)

    Total

    (Amounts in thousands)

    2008

    $
    326,000

    $
    —

    $
    6,366

    $
    9,425

    $
    341,791

    2009

    —

    2,368

    6,139

    7,703

    16,210

    2010

    —

    —

    5,912

    7,071

    12,983

    2011

    —

    —

    4,951

    6,577

    11,528

    2012

    —

    —

    4,498

    5,375

    9,873

    Thereafter

    —

    —

    10,844

    16,615

    27,459

    Total

    $
    326,000

    $
    2,368

    $
    38,710

    $
    52,766

    $
    419,844

    (1)

    Estimates of future interest payments for Short-Term Borrowings have been excluded in
the tabular presentation. See Notes to Consolidated Financial Statements for the variable
interest rates related to Short-Term 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)

    Estimates of future interest payments for Long-Term Debt have been included in the
tabular presentation based on the effective fixed and variable interest rates as of
September 30, 2007. The total estimated interest expense included is approximately $7.8
million. See Notes to Consolidated Financial Statements for the borrowings terms and fixed
or variable interest rates.

    (4)

    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.

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SEC Comment

Item 9A. Controls and 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 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 state, if true, that your chief executive officer and chief
financial officer also 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 disclosures. Alternatively, you could revise to simply state that your chief
executive officer and chief financial officer concluded disclosure controls and procedures
are effective.

Company response:

We will modify the disclosure to read as follows:

Evaluation of Disclosure Controls and Procedures

We maintain disclosure controls and procedures that are designed to ensure that
material information required to be disclosed by us in Securities Exchange Act
reports is recorded, processed, summarized and reported within the time periods
specified in the Securities and Exchange Commission’s rules and forms, and that such
information is accumulated and communicated to our management, including the Chief
Executive Officer and Chief Financial Officer, as appropriate, to allow timely
decisions regarding required disclosure.

Our Chief Executive Officer and Chief Financial Officer have evaluated the
effectiveness of the design and operation of our disclosure controls and procedures
(as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of
1934) as of the end of the period covered by this report. Based on such evaluation,
such officers have concluded that, as of the end of the period covered by this
report, our disclosure controls and procedures were effective.

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

Compensation Discussion and Analysis, page 6

    4.

    We note your response to prior comments eight 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.

Company Response

          You have requested that we provide you with disclosure that we would expect to provide
in the future filings regarding quantitative disclosure of pre-determined goals that our
compensation committee established for the executive incentive compensation plan. There are
several problems with this request.

          First, we point out that the compensation committee each year establishes individual
compensation plans for each of our executive officers. As a result, it is not possible to
describe expected disclosure for any future year.

          Second, we point out that quantitative disclosure of goals would cause us serious
competitive harm. The committee establishes performance goals to drive overall company
performance. Each officer has specific goals tied to that officer’s area of responsibility
in alignment with overall company objectives. The goals are aspirational in nature rather
than anticipatory in nature. That is, it would be misleading in various instances to
quantify a goal because our company does not necessarily set goals within guidance levels or
anticipated company performance. For example, we may have no idea whether we will open a
new retail location during a year and be unwilling from a liability standpoint to indicate a
targeted location opening level. Nevertheless, we may provide incentive compensation to one
of our officers for successfully opening one or more retail locations. Moreover, individual
goals often go to the core of corporate strategies, such as a reduction of inventory, an
increase in gross margin, raising additional capital, and securing the services of executive
personnel with specific expertise. Quantitative disclosure in these areas would involve
competitive harm with competitors, suppliers, and employees. For example, it would be
harmful for a competitor to know that we wanted to encourage reducing inventory by a
specific amount or increase margin by a specific percentage.

          We would expect discussions in future filings to be similar to the discussions
contained in our most recent proxy statement. However, the specific goals are likely to
change over time. We believe that we have disclosed a significant amount of information
about the targets and the computations to achieving the targets. Many of these objectives
are clear to a reader and easy to calculate.

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SEC Comment

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.

Company Response

     In future filings, we will disclose why we have chosen to make certain payment arrangements.

SEC Comment

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
the policies and procedures for the review, approval or ratification of the transactions
described in this section.

Company Response

     In future filings, we expect our disclosures to be similar to the following:

CERTAIN TRANSACTIONS AND RELATIONSHIPS

     Policy Relating to Certain Transactions

          We have a policy that we will not enter into any material transaction in which
a director or officer has a direct or indirect financial interest unless the
transaction is determined by our board of directors to be fair to us or is approved
by a majority of our disinterested directors or by our stockholders, as provided
for under Delaware law. The following transactions have been reviewed and approved
by our disinterested members of our board of directors.

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SEC Comment

Notes to Consolidated Financial Statements, page F-8

    7.

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

Company Response

     The company will add the following disclosure to page F-13 under the subsection “Revenue
Recognition”.

     The following table sets forth percentages of our revenue generated by certain products and
services, for each of last three years.

    2005

    2006

    2007

    New boat sales

    70.5
    %

    70.9
    %

    68.2
    %

    Used boat sales

    17.6
    %

    17.0
    %

    18.8
    %

    Maintenance and repair services

    4.6
    %

    4.9
    %

    5.0
    %

    Finance and insurance products

    3.1
    %

    3.2
    %

    3.6
    %

    Parts and accessories

    3.0
    %

    2.9
    %

    3.2
    %

    Brokerage services

    1.2
    %

    1.1
    %

    1.2
    %

    Revenue

    100.0
    %

    100.0
    %

    100.0
    %

     Thank you for the comments associated with review of our filings. We have attempted to
respond fully with the comments provided to ensure the adequacy and accuracy of our filings. It is
our intention to file amendments to the documents, as soon as administratively practical, once we
have concluded on the proper resolution of the staff’s comments. If you have any questions please
contact myself, Mike McLamb our CFO at 727-531-1700x10131 or Jack Ezzell our Chief Accounting
Officer and Controller at 727-531-1700x10107.

Sincerely,

Mike McLamb, CFO

MarineMax, Inc.

727-531-1700x10102

    Cc:

    Bill McGill — MarineMax, Inc.

    Bob Kant — Greenberg Traurig

    Mike Poland — E&Y

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