SecProbe.io

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                                             ONE SHELL PLAZA     AUSTIN
                                             910 LOUISIANA       BAKU
(BAKER BOTTS LLP LETTERHEAD)                 HOUSTON, TEXAS      DALLAS
                                             77002-4995          HOUSTON
                                             713.229.1234        LONDON
                                             FAX 713.229.1522    MOSCOW
                                                                 NEW YORK
                                                                 RIYADH
                                                                 WASHINGTON

April 29, 2005

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

        Attention:   Filing Desk

        Re:  Transocean Inc.

             Response to SEC Staff Comments sent by a letter dated April 1, 2005

Ladies and Gentlemen:

         On behalf of Transocean Inc. (the "Company"), we transmit herewith for
electronic filing via the EDGAR system a memorandum of the Company responding to
the comments received from the staff of the Division of Corporation Finance of
the Securities and Exchange Commission (the "Staff"), by a letter dated April 1,
2005 regarding the Company's Form 10-K, filed March 16, 2005 and response
letter, dated February 25, 2005 (File No. 333-75899).

         The Company's responses to the Staff's comments are included in the
memorandum enclosed herewith submitted on behalf of the Company. The Company is
separately transmitting certain portions of the memorandum and requesting
confidential treatment for the information under the Freedom of Information Act
("FOIA"). The location of information subject to the confidential treatment
request is indicated in the EDGAR submission with a statement in brackets to
that effect. The Company is also separately transmitting a portion of its
response to comment 2 as supplemental information (the "Supplemental
Information") and requesting confidential treatment for this supplemental
information under Rule 12b-4 under the Securities Act of 1934, as amended, and
the FOIA. Accordingly, this EDGAR transmission does not contain certain
designated portions of the memorandum or the Supplemental Information.

         Please telephone collect Gene J. Oshman (713.229.1178), John D. Geddes
(713.229.1113) or the undersigned (713.229.1749) of the firm Baker Botts L.L.P.,
counsel to the Company, with any questions or comments you may have regarding
the enclosed.

                                           Very truly yours,

                                           BAKER BOTTS L.L.P.

                                           By: /s/ James H. Mayor
                                               --------------------------------
                                                   James H. Mayor

cc:  Mr. William E. Turcotte
     Transocean Inc.

     Mr. Gene J. Oshman
     Mr. John D. Geddes
     Baker Botts L.L.P.
<PAGE>
                                             ONE SHELL PLAZA     AUSTIN
                                             910 LOUISIANA       BAKU
(BAKER BOTTS LLP LETTERHEAD)                 HOUSTON, TEXAS      DALLAS
                                             77002-4995          HOUSTON
                                             713.229.1234        LONDON
                                             FAX 713.229.1522    MOSCOW
                                                                 NEW YORK
                                                                 RIYADH
                                                                 WASHINGTON

                      FOIA CONFIDENTIAL TREATMENT REQUESTED
                               BY TRANSOCEAN INC.

                                                      James H. Mayor
                                                      713.229.1749
                                                      FAX 713.229.7849
                                                      james.mayor@bakerbotts.com

April 29, 2005

VIA HAND DELIVERY AND FACSIMILE

Ms. Jennifer Goeken
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W. Stop 04-05
Washington, D.C. 20549

Re:      Transocean Inc.
         Response to SEC Staff Comments sent by a letter dated April 1, 2005
         and Confidential Treatment Request

Dear Ms. Goeken:

         On behalf of our client, Transocean Inc. (the "Company"), provided
herewith are materials from the Company being submitted to the Securities and
Exchange Commission (the "Commission") in response to your comments sent by a
letter dated April 1, 2005 regarding the Company's Form 10-K, filed March 16,
2005 and response letter, dated February 25, 2005 (File No. 333-75899).

         Provided herewith are three copies of the Company's response to the
comments of the Staff (the "Submission"), including certain portions of the
Submission which are subject to a confidential treatment request. We are also
transmitting a graph as part of the Company's response to comment 2 of the Staff
contained in the April 1, 2005 comment letter, which is being provided to the
Commission as supplemental information under Rule 12b-4 of the Securities Act of
1934, as amended, and which is subject to a confidential treatment request (the
"Supplemental Information"). The EDGAR transmission of the Submission does not
contain certain designated portions of the Submission or the Supplemental
Information. We hereby request that the Staff return the Supplemental
Information to the undersigned in the enclosed self-addressed package after
completing its review. We believe that the return of such information is
consistent with the protection of investors and with the provisions of the
Freedom of Information Act (5 U.S.C. 552).

         If any member of the Staff has any questions relating to this
submission, we request such member to call Gene J. Oshman (713) 229.1178; John
D. Geddes at (713) 229.1113; or the undersigned at (713) 229-1749.

<PAGE>

(BAKER BOTTS LLP LETTERHEAD)

Ms. Jennifer Goeken                     2                         April 29, 2005

FOIA Confidential Treatment Request

         Pursuant to Rule 83 of the Commission's rules and regulations relating
to Commission records and information, 17 C.F.R. 200.83, we hereby request that
confidential treatment be accorded to portions of the Submission and the
Supplemental Information and that such material not be disclosed in response to
any inquiry under the Freedom of Information Act (5 U.S.C. Section 552). Please
promptly inform us of any request under the Freedom of Information Act or
otherwise so that we may substantiate this request for confidential treatment
according to Rule 83.

         All of the pages of the Submission and the Supplemental Information
being hand delivered to the Staff have been marked with a legend substantially
similar to the following: "Confidential Treatment Requested by Transocean Inc."

         In addition to its request for confidential treatment of the
above-referenced portions of the Submission and the Supplemental Information,
the Company requests that any memoranda, notes or other writings made by any
member or employee of the Commission relating to either of the foregoing or any
conference or telephone conversation with respect thereto and any copies of
extracts of any of the foregoing be withheld from public availability pursuant
to 5 U.S.C. Section 552(b)(4), and 17 C.F.R. Section 200.80(b)(4).

         A copy of this Confidential Treatment Request (without the attachments)
is being delivered to FOIA Officer of the Commission.

         Thank you for your attention to this matter.

                                             BAKER BOTTS L.L.P.

                                             By:  /s/ James H. Mayor
                                                  -----------------------------
                                                  James H. Mayor

<PAGE>

(BAKER BOTTS LLP LETTERHEAD)

Ms. Jennifer Goeken                     3                         April 29, 2005

                      FOIA CONFIDENTIAL TREATMENT REQUESTED
                               BY TRANSOCEAN INC.

cc:    (without attachments):

       Office of Freedom of Information and Privacy Act Operations
       Securities and Exchange Commission
       Operations Center
       6432 General Green Way
       Alexandria, Virginia  22312-2413

       Mr. H. Roger Schwall
       Mr. Barry Stem
       Securities and Exchange Commission

       Mr. William E. Turcotte
       Transocean Inc.

       Mr. Gene J. Oshman
       Mr. John D. Geddes
       Baker Botts L.L.P.
<PAGE>
               CONFIDENTIAL TREATMENT REQUESTED BY TRANSOCEAN INC.

                                                                  April 29, 2005

                                 TRANSOCEAN INC.

                    MEMORANDUM IN RESPONSE TO STAFF COMMENTS

                        Form 10-K, filed March 16, 2005,
          Response Letter dated February 25, 2005 (File No. 333-75899)

         This memorandum sets forth the responses of Transocean Inc. (the
"Company") to the comments of the Staff of the Division of Corporation Finance
contained in the letter dated April 1, 2005 from H. Roger Schwall, Assistant
Director, with respect to the Company's Form 10-K, filed March 16, 2005 and
response letter dated February 25, 2005 (File No. 333-75899).

                    10-K FOR THE YEAR ENDED DECEMBER 31, 2004

Business, page 3

         Transocean Drilling Fleet tables, pages 6-9

Comment

1.       We have read your response to prior comment 1, where you indicate that
         "cash flows from a rig are dependent upon other rigs within the asset
         class" because "the availability of another competing rig has a direct
         influence on the dayrates bid for a job and consequently the cash flow
         derived from that contract." While we recognized that the grouping of
         long-lived assets requires significant judgment, as indicated by
         paragraph B45 of SFAS 144, we do not believe that offsetting is
         appropriate within the asset class level because an individual rig can
         be an individual source of cash flows. Even though rigs within an asset
         class are interchangeable, that interchangeability can be influenced by
         your marketing through decisions to "cold stack" certain rigs with a
         particular market sector. Since you are capable of generating discrete
         financial information on an individual rig basis and individual rigs
         can be largely independent of one another based on marketing efforts,
         it appears that individual rigs are the lowest level for which
         identifiable cash flows are largely independent of the cash flows of
         other assets and liabilities.

Company Response

         To further discuss our asset groupings for impairment analysis under
         SFAS 144, we are providing additional information that we believe will
         provide a better understanding of how we view our fleet and the cash
         flows generated by our fleet in supporting asset values and,
         ultimately, our asset grouping for impairment review. At the outset we
         would like to point out that the estimated fair value of all but one of
         our cold stacked rigs exceeded their respective book values at March
         31, 2005. For the one rig where the estimated fair value was less than
         book value, we performed a high level projection of cash flows based on
         our current view of market conditions. We concluded that no impairment
         would have existed on any of those individual rigs.

                                      -1-
<PAGE>

               CONFIDENTIAL TREATMENT REQUESTED BY TRANSOCEAN INC.

         However, as explained below, we strongly believe the asset class is the
         appropriate level for which to perform our impairment analysis.

         Our business of drilling oil and gas wells is performed in a global,
         contract-driven auction market. Our customers, which consist largely of
         major international oil and gas companies and government
         owned/controlled oil and gas companies throughout the world, have
         drilling prospects across all geographic regions for which they
         periodically offer contracts for bid. The clients determine contract
         requirements for rigs, and the predominant characteristic is water
         depth capability. These contracts tend to be term contracts and are bid
         on a dayrate basis. The dayrate at which a given contract is awarded is
         driven by the worldwide supply and demand of the marketed rigs
         available for bid at the time. In a tight supply/high demand market,
         dayrate bids tend to be higher than in excess supply markets. Rigs are
         largely interchangeable within an asset class such that any number can
         be used to satisfy a given contract.

         Rigs are highly mobile and are easily relocated based on contract
         opportunity. Also, costs to mobilize a rig between geographic regions
         are typically recoverable, at least in part, from the customer and
         represent a small portion of our customer's overall cost of drilling a
         well. These costs can range from $[CONFIDENTIAL TREATMENT REQUESTED BY
         TRANSOCEAN INC.] to $[CONFIDENTIAL TREATMENT REQUESTED BY TRANSOCEAN
         INC.]. We, as well as our competitors, relocate drilling rigs as
         contract opportunities arise. These relocations tend to adjust
         temporary imbalances between supply and demand in a specific market
         sector. As a result, the global supply of rigs has an impact on the
         dayrates bid and ultimately accepted by our customers.

         Rig mobility can be seen from the statistics provided in our earlier
         response. As noted in that response, within the global Other Floater
         rig fleet consisting of 120 rigs, there were 294 inter-regional rig
         moves and 603 inter-country rig moves during the period of 1995 through
         2004. Over the last 20 years, each of these rigs has, on average,
         relocated between countries of operations every two years and between
         regions every five years. Similarly, we have seen significant movement
         between major regions (the Americas, Europe/Africa and Asia) within our
         own fleet. We had seven of such rig moves during 2004, five in 2003 and
         six in 2002. At a country level, our rig moves are even more prevalent
         with 25 moves in 2004, 31 moves in 2003 and 33 moves in 2002.

         The contract drilling business is highly cyclical, and dayrates are
         heavily influenced by the availability of a relatively small number of
         competing rigs for any given contract opportunity. As demand decreases,
         the market can quickly become oversupplied with rigs as they come off
         contract with no potential follow-on work. Conversely, increases in
         demand absorb the supply of rigs available for bid, with rig
         construction/modification and bringing rigs out of cold stack being the
         only readily available source of additional marketed rigs. This
         supply/demand dynamic is evidenced, for example, by the high
         correlation among geographic regions for dayrates as described on page
         5 of our previous response to the Staff.

                                      -2-
<PAGE>

               CONFIDENTIAL TREATMENT REQUESTED BY TRANSOCEAN INC.

         We manage our rigs and the associated stacking decisions on an asset
         class basis and not on an individual rig basis. These decisions are
         made in order to optimize cash fl