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National
Energy Services Reunited Corp.

777
Post Oak Blvd., Suite 730

Houston,
Texas, 77056

April
23, 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:
John Reynolds, Assistant Director

    Re:
    National
    Energy Services Reunited Corp.

    Amendment
    No. 1 to Preliminary Proxy Statement on Schedule 14A

    Filed
    April 2, 2018

    File
    No. 001-38091

Dear
Mr. Reynolds:

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 April 17, 2018, regarding our Amendment No. 1 to Preliminary
Proxy Statement on Schedule 14A (the “Proxy Statement”) previously filed on April 2, 2018. NESR has filed today
Amendment No. 2 to the Proxy Statement (“Amendment No. 2”).

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.

General

    1.
    We
    have considered your responses to comments 2 and 4. Please further revise your disclosure to identify the principal parties
    participating in the backstop arrangement. Similarly, please identify those individuals exercising dispositive power over
    shares to be acquired by any entity. If you do not intend to file the finalized agreement prior to distribution of the definitive
    proxy, please explain to us the reasons for that approach.

Response:
 In response to Staff’s comment, the counter party to the Forward Purchase Agreement (“FPA”) is MEA
Energy Investment Company 2 Ltd. (“MEA Energy Co”) which is an indirect wholly owned subsidiary of Waha
Capital PJSC (“Waha”). MEA Energy Advisory UK LLP (“MEA Energy LLP”) arranged the Backstop
Commitment and has recently become affiliate of Waha due to a recent change in management of Waha. MEA Energy
Co has been advised NESR that the individual investors in the NESR shares to be issued and sold pursuant
to the FPA will invest through NESR SPV Limited, a wholly owned subsidiary of MEA Energy Co, And are not related
to Castle SPC Limited or Waha and will not have voting or dispositive power over the shares sold to MEA Energy Co.

MEA
Energy Co will continue to have direct, and Waha will have ultimate, voting and dispositive power over the NESR shares to be issued
and sold pursuant to the FPA.

The
Company will file the finalized FPA prior to distribution of the definitive proxy.

The
Company has revised page 29 of Amendment No. 2 with an updated chart of the expected ownership following
the consummation of the transaction:

    (1)
    Castle SPC Limited.
    is wholly owned by Waha Capital PJSC; Backstop Investor MEA Energy Investment Company 2 Ltd is wholly owned by Waha Capital
    PJSC and has sole dispositive power over shares sold to MEA Energy Investment Company 2 Ltd.

    (2)
    Competrol Establishment,
    which participated in the IPO, is a subsidiary of The Olayan Group and will own 3.12% of NESR post Business Combination (page
    250) assuming no redemptions. Hana Investments Co WLL is also a subsidiary of The Olayan Group and the total holdings
    controlled by The Olayan Group post Business Combination will be 17.41% assuming no redemptions. Hana Investments Co WLL bought
    an interest in NPS pursuant to the NPS Stock Purchase Agreement.

    (3)
    GES Selling Shareholders
    include Mubadarah Investments, LLC, Yasser Said Al Barami and Hilal Al Busaidy who are selling 61% of the outstanding shares
    of GES and will hold 19.2% of NESR post Business Combination assuming no redemptions.

    (4)
    SV3 Holdings Pte
    Ltd is owned by two private equity funds: SCF-VIII, L.P., and Viburnum Funds Pty Ltd.

    (5)
    NESR Holdings Ltd,
    the sponsor of NESR, acquired 11.7% of the outstanding shares of GES with funding from 11 investors (GES Investors). NESR
    Holdings Ltd has agreed to a Shares Exchange Agreement by which it will assign all of its GES shares to NESR, upon
    the closing of the business combination.

    (6)
    Hussain Al Nowais
    has a 7.56% ownership interest in Waha Capital and is the Chairman of Al-Nowais Investments LLC.

John
Reynolds, Assistant Director

U.S.
Securities and Exchange Commission

April
23, 2018

Page
2 of 7

    2.
    In
    your response to prior comment 3, you state in part: “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.” Absent additional explanation and context, the reader is unaware of the basis for these assertions.
    If you continue to make references to “key metrics” and the purported outperformance by the Target Companies of
    its peers, revise to identify those metrics and provide additional contextual explanations for your related assertions.

Response:
In response to Staff’s comment, the Company has revised pages 27 and 172 of Amendment No. 2 to remove the
statements that “NPS is one of the largest regionally-owned oil, gas and petrochemical services providers of the businesses
in which it operates in the Middle East” and that the Target Companies “have outperformed their peers in key financial
metrics.” The Company believes these statements to be true and supported by the information previously provided to Staff
supplementally on a confidential basis pursuant to Rule 12b-4 of the Exchange Act. However, the Company believes that such information
is of a proprietary and sensitive nature and therefore has elected not to include such statements in the proxy statement.

Reasons
for the Business Combination, page 31

    3.
    We
    have considered your revisions in response to comment 6 and your reference to a period ending in December 2017. Please balance
    your updated disclosure in this section by including a discussion regarding current U.S. macro trends, such as increasing
    production from U.S. shale exporters and the resultant impact on anticipated global oversupply.

    Response:
    In response to the Staff’s comment, NESR has revised page 31 of Amendment No. 2 to add the following additional
    discussion of macro trends impacting U.S. and global energy markets:

  “From a macro market perspective, over the short term, the United States Energy Information Administration (“EIA”)
in its Short Term Energy Outlook (“STEO”) report published in April 2018 (https://www.eia.gov/outlooks/steo/archives/apr18.pdf)
estimates that U.S. crude oil production averaged 10.4 million barrels per day (“b/d”) in March 2018, up 260,000 b/d
from the February 2018 level. Total U.S. crude oil production averaged 9.3 million b/d in 2017. EIA projects that U.S. crude oil
production will average 10.7 million b/d in 2018, which would mark the highest annual average U.S. crude oil production level,
surpassing the previous record of 9.6 million b/d set in 1970. EIA forecasts that 2019 crude oil production will again increase,
averaging 11.4 million b/d. EIA also states that commercial crude oil inventories in the United States fell lower than the previous
five-year average for the week ending March 16, 2018, the first time inventories were lower than the five year average since 2014.
Large inventory declines in the United States during the past year contributed to the 267 million barrel decline in total petroleum
inventories since January 2017 in countries in the Organization for Economic Cooperation and Development (“OECD”),
which are estimated to be 2.8 billion barrels as of the end of March 2018. In the March STEO, EIA estimated that inventories
of global petroleum and other liquid fuels declined by 0.6 million b/d in 2017. Despite these supply developments, EIA estimates
that demand-side factors could have tempered some of the upward oil price pressures in recent weeks. Both the United States and
China announced potential tariffs on several billion dollars’ worth of each other’s goods in March 2018. A
slowdown in global trade could affect oil demand and presents downside risks to the global oil consumption forecast, although
the forecast was revised higher from EIA’s previous STEO. EIA forecasts that global oil consumption will grow by 1.8 million
b/d in both 2018 and 2019. EIA forecasts Brent spot prices will average about $63/b in both 2018 and 2019 and estimated in its
March STEO that global inventories will grow by about 0.4 million b/d in 2018 and by another 0.3 million b/d in 2019.

John
Reynolds, Assistant Director

U.S.
Securities and Exchange Commission

April
23, 2018

Page
3 of 7

Over
the long term, in the EIA annual report on International Energy Outlook for 2017 (“IEO2017”), in the reference case
used for projections in IEO2017 total world energy consumption rises by 28%. It further projects that in the reference case most
of the world’s energy growth will occur in countries outside of the OECD, where strong, long-term economic growth drives
increasing demand for energy. In the long term, the IEO2017 projects increased world consumption of marketed energy from all fuel
sources—except coal, where demand is essentially flat—through 2040. Global natural gas consumption increases by 1.4%/year.
Abundant natural gas resources and rising production—including supplies of tight gas, shale gas, and coalbed methane—contribute
to the strong competitive position of natural gas. Liquid fuels—mostly petroleum-based—remain the largest source of
world energy consumption. However, the liquids share of world marketed energy consumption falls from 33% in 2015 to 31% in 2040,
as oil prices rise steadily, leading many energy users to adopt more energy-efficient technologies and to switch away from liquid
fuels when feasible.

IEO2017
projects world use of petroleum and other liquid fuels grows from 95 million b/d in 2015 to 104 million b/d in 2030 and to 113
million b/d in 2040. To satisfy the increase in world liquids demand in the IEO2017, petroleum and other liquid fuels production
increases by 16.1 million b/d from 2015 to 2040. The IEO2017 assumes that countries in the Organization of Petroleum Exporting
Countries (“OPEC”) will invest in incremental production capacity to maintain a 39%–44% share of total world
liquids production through 2040, consistent with their share over the past 15 years with most of the increase coming from the
Middle East. To meet the growth in natural gas demand projected in the IEO2017, the world’s natural gas producers increase
supplies by 42% from 2015 to 2040. The largest increases in natural gas production from 2015 to 2040 occur in the Middle East,
China, the United States and Russia. In Russia, production growth is supported primarily by increasing development of resources
in the country’s Arctic and eastern regions. U.S. production growth comes mainly from shale resources. In China, most growth
in the long-term comes from the country’s development of its shale resources, which are projected to account for more than
half of its total natural gas production in 2040.”

Unaudited
Pro Forma Condensed Combined Financial Information, page 67

    4.
    We
    have reviewed your response to prior comment 8 and your analysis of the factors pursuant to ASC 805-10-55-11 and ASC 805-10-55-12
    to support your conclusion that NESR is the accounting acquirer. You state “the outside investors are not affiliated
    with Targets.” However, it is unclear whether this statement applies to the Backstop Investor. Please tell us whether
    the Backstop Investor is related to NESR, NPS or GES. If the Backstop Investor is affiliated with or otherwise related to
    one of these entities, provide us with an updated analysis as to how this relationship impacts your conclusion that NESR is
    the accounting acquirer under the minimum and maximum redemption scenarios.

Response:
In response to the Staff’s comment, we have been recently advised that the dispositive powers on the NESR shares
issued to the entity that will execute the Forward Purchase Agreement, MEA Investment Company 2 Ltd., will reside with Waha
Capital PJSC (“Waha”) as employees of Waha hold all Board of Director positions at MEA Energy Investment Company 2
Ltd. MEA Energy Investment Company 2 Ltd will own 100% of the voting rights of NESR SPV Limited, who will acquire the NESR shares
and individual investors funding the backstop will hold non-voting shares in NESR SPV Limited. Waha has a 21% ownership stake
in NPS. Though the underlying investors in NESR SPV Limited are not affiliated with NPS, GES or NESR, because of the dispositive
power held by Waha we have adjusted our analysis to allocate the Backstop Investors to NPS. We have revised our disclosure in
Amendment No. 2 to indicate that the backstop facility is affiliated with NPS. However, for the purposes of the accounting
acquirer determination, we do not believe this changes the conclusion of NESR as the accounting acquirer. When considering the
composition of voting interests it should be noted that while Hana Investments Co. WLL (“Hana”) has acquired an interest
in NPS, its voting interest has been attributed to NESR. This is because of the affiliation to NESR of Hana via The Olayan Group’s
(“Olayan”) 100% ownership in Hana and sole dispositive power over NESR shares issued to Hana.

Hana
invested $150 million in NPS on January 14, 2018 pursuant to the NPS Stock Purchase Agreement which stipulated that Hana
would invest in NPS and Hana agreed to exchange its shares in NPS for NESR shares at an agreed exchange rate at closing of the
Business Combination. Olayan also has sole dispositive power over NESR shares owned by Competrol Establishment, an investor
in NESR at the initial public offering and currently holds a 10.47% interest in NESR. The investment of Hana in NPS would not
have happened if NESR had not put this transaction together as it is only because of NESR and its management team’s
expertise and know how that Hana agreed to make such an investment.

The
voting interest across the parties, after the allocation of the Backstop Investors to NPS, would be as follows:

    Minimum
    Redemption
    Maximum
    Redemption

    NESR
      44 %
      39 %

    NPS
      27 %
      29 %

    GES
      29 %
      32 %

With
majority voting required for significant shareholder actions no one entity has control based solely on voting
interest in either scenario. Therefore, we continue to believe that the factors described previously demonstrate that NESR is
the accounting acquirer in both minimum and maximum redemptions scenarios shown.

John
Reynolds, Assistant Director

U.S.
Securities and Exchange Commission

April
23, 2018

Page
4 of 7

Notes
to Unaudited Pro Forma Condensed Combined Financial Information, page 72

Note
3. GES Historical Financial Statements, page 76

Adjustments
to Unaudited Pro Forma Condensed Combined Balance Sheet, page 78

    5.
    We
    note that pro forma adjustment (a) includes two adjustments, one for the difference in the basis of presentation between IFRS
    and US GAAP and the other for the impairment of goodwill in fiscal 2017. Additionally, we note that pro forma adjustment (aa)
    reflects the full impairment in fiscal 2017 of goodwill. However, Note 5 per page F-66 shows that GES fully impaired its goodwill
    balance in fiscal 2016. Please clarify for us why these adjustments are described as impacting fiscal 2017.

Response:
In response to the Staff’s comment, we have revised the disclosure on pages 72-83 of Amendment No. 2 to exclude
the impairment charge from 2017 as it would hav