SecProbe.io

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								September 2, 2005

Mr. Christian Mowinckel
Interim Managing Director and Vice President-Finance
Ocean Rig ASA
Koppholen 4
4313 Sandnes, Norway

	Re:	Ocean Rig ASA
		Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 10, 2005
      File No. 333-09110

Dear Mr. Mowinckel:

      We have reviewed your filing and have the following comment.
We have limited our review of your filing to those issues we have
addressed in our comment.  Please provide a written response to
our
comment.  Please be as detailed as necessary in your explanation.
In
some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.  After reviewing this
information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 20-F for the Fiscal Year Ended December 31, 2004

1. We note the disclosure in your filing regarding Eirik Raude`s
drilling offshore Cuba for Repsol YPF.  In light of the fact that
Cuba is identified as a state sponsor of terrorism by the U.S.
State
Department, and is subject to economic sanctions administered by
the
U.S. Treasury Department`s Office of Financial Assets Control,
please
describe for us more fully Eirik Raude`s operations offshore Cuba,
including the material terms of your contract with Repsol, and the
dollar amount of revenue you received from Repsol in connection
with
this drilling activity.
Please advise us of your view as to the materiality to you of
Eirik
Raude`s operations offshore Cuba, and whether they constitute a
material investment risk for your security holders.    In
preparing
your response, please consider that evaluations of materiality
should
not be based solely on quantitative factors, but should include
consideration of all factors that a reasonable investor would deem
important in making an investment decision, including the
potential
impact of corporate activities upon a company`s reputation and
share
value.    In this regard, we note that legislation requiring
divestment from, or reporting of interests in, companies that do
business with U.S.-designated state sponsors of terrorism recently
has been adopted by Arizona and Louisiana.

Closing Comments

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Gary Newberry at (202) 551-3761 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3684 with any other
questions.

								Sincerely,

								April Sifford
								Branch Chief

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Mr. Christian Mowinckel
Ocean Rig ASA
September 1, 2005
page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, N.E.
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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