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CORRESP
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National
Energy Services Reunited Corp.

777
Post Oak Blvd., Suite 730

Houston,
Texas, 77056

April
2, 2018

VIA
EDGAR

U.S.
Securities and Exchange Commission

Office
of Natural Resources

100
F Street, N.E.

Mail
Stop 4628

Washington,
DC 20549

Attn:
H. Roger Schwall, Assistant Director

    Re:
    National
    Energy Services Reunited Corp.

    Preliminary
    Proxy Statement on Schedule 14A

    Filed
    February 14, 2018

    File
    No. 001-38091

Dear
Mr. Schwall:

National
Energy Services Reunited Corp. (“NESR”, “we”, “us” or “our”)
hereby transmits its response to the comment letter received by us from the staff (the “Staff”) of the Securities
and Exchange Commission (the “Commission”), dated March 14, 2018, regarding our Preliminary Proxy Statement
on Schedule 14A (the “Proxy Statement”) previously filed on February 14, 2018. NESR has filed today Amendment
No. 1 to the Proxy Statement (“Amendment No. 1”).

Our
responses below correspond to the captions and numbers of the Staff’s comments. For the convenience of the Staff, we have
reproduced those comments below in bold and our response to each comment immediately follows the applicable comment. Capitalized
terms used in this letter but not otherwise defined have the meanings assigned to them in Amendment No. 1.

In
addition to submitting this letter by EDGAR, we will also deliver to the Staff a copy of this letter together with Amendment No.
1 marked to show revisions we have made to the Proxy Statement, including revisions made in response to the Staff’s comments.

General

    1.
    With
    your revised proxy statement, provide updated disclosures regarding significant developments. For example, please disclose
    the status of the exemption application to which you refer at page 46. Similarly, your answer at page 21 under “What
    happens if I vote against...?” emphasizes that you would need to dissolve and liquidate, but this appears to discount
    the possibility that the company would be able to actively solicit and pursue other possible transactions prior to the May
    2019 deadline.

Response:
In response to the Staff’s comment, NESR has updated all disclosures in Amendment No. 1 where there have been significant
developments since the filing of the Proxy Statement on February 14, 2018, including but not limited to the status of the exemption
application referenced on page 46 (which status has been updated on page 26).

H.
Roger Schwall, Assistant Director

U.S.
Securities and Exchange Commission

April
2, 2018

Page 2 of 19

In
addition, in response to the Staff’s comment, NESR has revised the disclosure to the answer on page 21 under “What
happens if I vote against...?” to include the following language in Amendment No. 1:

“If
the Business Combination Proposal is not approved, we may proceed to identify another transaction which may be submitted for shareholder
approval. If we are ultimately unable to consummate a Business Combination and close such transaction by May 17, 2019, then we
will be required to dissolve and liquidate our trust account by returning the then remaining funds in such account to the public
shareholders.”

Questions
and Answers about the Proposals for Shareholders

Q:
What equity stake will (i) current NESR shareholders . . . page 18

    2.
    Please
    revise to include a separate question and answer in which you identify the Backstop Investor and address its maximum potential
    holdings upon consummation of the transaction.

Response:
In response to the Staff’s comment, NESR has included the following question and answer in Amendment No. 1 on page 18:

“Q:
Who is the Backstop Investor and what will be their minimum and maximum potential holdings upon the consummation of the transaction?

A:
The Backstop Investor is party(ies) arranged by MEA Energy Advisory UK, LLP or its affiliates who are providing the Backstop
Commitment.

Assuming
no redemptions occur and NESR does not exercise its option to draw an additional $80 million under the Backstop Commitment, the
Backstop Investor, following completion of the Business Combination, will own a minimum of 7,000,000 ordinary shares at $10.00
per share, which will represent an ownership interest of 7.9% in NESR, and NESR’s public shareholders will retain an ownership
interest of 25.7% in NESR.

In
the event NESR exercises its option to draw the full additional amount under the Backstop Commitment of $80 million in exchange
for 7,114,906 ordinary shares at $11.244 per share and assuming no redemptions occur, then following completion of the Business
Combination the Backstop Investor will have an ownership interest of 14.7% in NESR, and NESR’s public shareholders will
retain an ownership interest of 23.8% in NESR.”

H.
Roger Schwall, Assistant Director

U.S.
Securities and Exchange Commission

April
2, 2018

Page
3 of 19

Summary
of the Proxy Statement, page 26

General

    3.
    We
    note your reference in this section to NPS Holdings Limited as the “largest regionally-owned oil, gas and petrochemical
    services provider in the Middle East.” At page 31, you assert that the Target Companies “have ... outperformed
    their peers in key financial metrics.” Please identify the “key metrics” to which you refer, and supplementally
    provide us with highlighted copies of the materials, both publically available and customer-prepared, that served as the basis
    for these assertions.

Response:
In response to the Staff’s comment, NESR has revised the disclosures on pages 27 and 171 of Amendment No. 1 from “the
largest regionally-owned oil, gas and petrochemical services provider in the Middle East” to “one of the largest regionally-owned
oilfield services providers of the businesses in which it operates in the Middle East”. Since most of the regional oilfield
services companies in the MENA region are privately held companies and hence public information is not available for them, we
based our assertions on NPS management’s knowledge of the size of each competitor’s operations and information procured
by a third-party evaluation firm.

In
response to the Staff’s request, NESR has provided to the Staff, under separate cover (all information included in that
submission, the “Supplemental Information”) on a confidential and supplemental basis pursuant to Rule 12b-4
of the Exchange Act (“Rule 12b-4”), hard copies of extracts of information procured by a third-party evaluation
firm. In accordance with such rule, the Supplemental Information was provided together with a request that such information either
be returned or shredded (and provide us with acknowledgement of same) promptly following completion of the Staff’s review
thereof. Such materials are not, and will not be, filed with or deemed to be part of the Proxy Statement or any amendments thereto.
A request for confidential treatment of such materials pursuant to the provisions of 17 C.F.R. § 200.83 has also been made
under separate cover.

With
respect to the language on page 31 referenced in the Staff’s comment, NESR has also provided to the Staff in the Supplemental
Information hard copies of the “Key Metrics” referred to on page 31 and referenced in the Staff’s comment. In
accordance with Rule 12b-4, the Supplemental Information was provided on a confidential and supplemental basis together with a
request that such information either be returned or shredded (and provide us with acknowledgement of same) promptly following
completion of the Staff’s review thereof. Such materials are not, and will not be, filed with or deemed to be part of the
Proxy Statement or any amendments thereto. A request for confidential treatment of such materials pursuant to the provisions of
17 C.F.R. § 200.83 has also been made under separate cover.

Organizational
Structure, page 28

    4.
    Please
    expand the diagram or provide an additional chart to illustrate the anticipated holdings of the Backstop Investor, GES Selling
    Stockholders, NPS Selling Stockholders, and your sponsor upon consummation of the contemplated transactions.

Response:
In response to the Staff’s comment, please see below an additional chart to illustrate the anticipated holdings of the
Backstop Investor, GES Selling Stockholders, NPS Selling Stockholders, and the Sponsor, as well as the remaining shareholders,
upon consummation of the contemplated transactions, assuming no redemptions and utilization of the full $150 million Backstop
Commitment. This chart has been added to page 29 of Amendment No. 1.

H.
Roger Schwall, Assistant Director

U.S.
Securities and Exchange Commission

April
2, 2018

Page
4 of 19

Consideration
for the Acquisition of GES in the Business Combination, page 28

    5.
    Revise
    to clarify where footnotes 1 and 3 should be shown in the table summarizing the consideration for the acquisition of NPS and
    GES.

Response:
In response to the Staff’s comment, the referenced table has been revised on page 28 of Amendment No. 1 as follows to
clarify the footnote references:

    NESR Ordinary
 Shares
    Cash
 (in millions)

    NPS Selling Stockholders(2)
      11,318,827
    $ 292.8

    Hana Investments(3)
      13,758,449
      -

    Total for NPS
      25,077,276
    $ 292.8

    GES Selling Stockholders
      18,484,848
      -

    SV3 Holdings Pte Ltd
      6,825,000
      -

    NESR Holdings Ltd/ GES Investors(4)
      2,925,000
      -

    Total for GES
      28,234,848
      -

    Total for NPS and GES transactions
      53,312,125
    $ 292.8 (1)

1Part
of the proceeds from the Forward Purchase Agreement will be used to help finance the cash consideration payable to the NPS Selling
Stockholders.

2
Excludes possible Cash Earnout, Equity Earnout and Ticker Fee as described in the Consideration for the Acquisition of NPS.

3Includes
418,001 NESR ordinary shares to be issued as payment for $4.7 million interest accrued for Hana Investments.

4Excludes
interest on the loans of approximately $1.25 million payable in cash to the GES Investors.

H.
Roger Schwall, Assistant Director

U.S.
Securities and Exchange Commission

April
2, 2018

Page
5 of 19

Reasons
for the Business Combination, page 31

    6.
    Provide
    updated disclosure regarding current market conditions. You state that “overall MENA drilling activity has not declined
    over the last three years while, in comparison, the United States drilling rig counts dropped considerably.”

Response:
In response to the Staff’s comment, NESR revised the disclosure on pages 31 and 109 of Amendment No. 1 by deleting the
referenced sentence and replacing it with the following two sentences:

“Overall
Middle East drilling activity has not declined materially over the last three years while, in comparison, the United States drilling
rig count has dropped considerably, as evidenced by the February 2018 Baker Hughes World Wide Rig Count Report stating that since
2014, the monthly average Middle East rig count has dropped less than 1% from January 2015 to December 2017 while the monthly
average rig count in the United States dropped 50% over the same three-year period.”

The
information is located on the Baker Hughes GE website at the following link: http://phx.corporate-ir.net/phoenix.zhtml?c=79687&p=irol-rigcountsoverview

Selected
Historical Financial Information of GES, page 34

    7.
    Provide
    disclosure stating the selected financial data of GES presented here is prepared in accordance with International Financial
    Reporting Standards as issued by the International Accounting Standards Board.

Response:
In response to the Staff’s comment, NESR has revised the disclosure on page 34 of Amendment No. 1 to state that the
selected financial data of GES has been prepared in accordance with International Financial Reporting Standards as issued by the
International Accounting Standards Board.

Unaudited
Pro Forma Condensed Combined Financial Information, page 67

    8.
    As
    it relates to the acquisition of NPS and GES, we note the factors you cite on page 69 in support of your conclusion that NESR
    is the accounting acquirer pursuant to ASC 805. Please provide us with your complete analysis in support of the conclusion
    that NESR is the accounting acquirer. Your response should provide further information regarding the relative voting rights
    in the combined entity, with consideration given to minimum and maximum redemption scenarios.

Response:
In response to the Staff’s comment, NESR respectfully submits additional detail of its previous accounting acquirer
evaluation in accordance with ASC 805.

To
determine the accounting acquirer, NESR considered the different elements stipulated in ASC 805. NESR evaluated the consideration
exchanged, the size of the entities involved, as well as the factors present in ASC 805-10-55-11 and ASC 805-10-55-12. Additionally,
NESR also reviewed ASC 805-40 to determine if the Business Combination would be considered a forward or reverse acquisition.

The
form of the Business Combination includes a mix of cash and equity-based consideration issued by NESR to the shareholders of two
operating companies. In this form of transaction, the accounting acquirer may not be the legal acquirer. Based on NESR’s
analysis of the facts and circumstances of the Business Combination, NESR concluded that it was the accounting acquirer.

H.
Roger Schwall, Assistant Director

U.S.
Securities and Exchange Commission

April
2, 2018

Page
6 of 19

NESR’s
conclusion was based on five primary factors, summarized below and also discussed in further detail, which hold true for both
the minimum and maximum redemption scenarios:

    ●
    NESR
    is transferring cash via the use of funds in NESR’s trust account, issuing NESR ordinary shares, and will be incurring
    liabilities to execute the Business Combination;

    ●
    NESR
    has the right to nominate 4 out of the 9 initial members who will serve on the Board of Directors of the post-closing combined
    company. Furthermore, NESR’s Chief Executive Officer will be the Chairman of the Board of the combined company. This
    provides a plurality for NESR with no other company representing more than 3 seats on the Board of the combined company. There
    are also no special voting rights conveyed in the Business Combination;

    ●
    NESR’s
    executive management team will comprise the executive management of the combined company;

    ●
    NESR
    was the entity that initiated the Business Combination; and

    ●
    The
    headquarters of the combined company will be NESR’s headquarters.

An
analysis of ASC 805 in view of these five factors is provided below:

Transfers
cash / incurs indebtedness / Issuer of equity

Per
ASC 805-10-55-11:

In
a business combination effected primarily by transferring cash or other assets or by incurring liabilities, the acquirer usually
is the entity that transfers the cash or other assets or incurs the liabilities.

Per
ASC 805-10-55-12:

In
a business combination effected primarily by exchanging equity interests, the acquirer usually is the entity that issues its equity
interests.

To
consummate the Business Combination, NESR will issue its equity to shareholders of the Targets, in addition to outside investors
who have put in capital to fund the Business Combination. NESR will also use its funds sitting in trust as a source of the cash
portion of the consideration in the Business Combination. No other party or entity is issuing new equity interests in the Business
Combination. This favors NESR as the accounting acquirer in the Business Combination.

Furthermore,
NESR is incurring liabilities as it will assume the obligation to satisfy the Loan Contracts with the GES Investors. Additionally,
outside investors will contribute cash. The outside investors are not affiliated with Targets, and the capital contributed by
them is convertible into shares of NESR at a pre-defined per share price. N