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CORRESP
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National
Energy Services Reunited Corp.

777
Post Oak Blvd., Suite 730

Houston,
Texas, 77056

    May
    7, 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. 2 to Preliminary Proxy Statement on Schedule 14A

    Filed
    April 23, 2018

    File
    No. 001-38091

Dear
Mr. Reynolds:

National
Energy Services Reunited Corp. (“NESR”, “we”, “us” or “our”)
hereby transmits its response to an oral comment received by us from the staff (the “Staff”) of the Securities
and Exchange Commission (the “Commission”) on May 3, 2018, regarding our Amendment No. 2 to Preliminary Proxy
Statement on Schedule 14A (the “Proxy Statement”).

For
the convenience of the Staff, we have reproduced your oral comment below in bold and our response immediately follows the comment.

    1.
    We
    note your response to comment 8 from our letter to you dated April 17, 2018. You continue to omit significant portions of
    the detailed 5-year revenue projections, valuated on both a segment and geographic basis, as well as certain growth assumptions.
    In your next revised proxy statement, provide enhanced disclosure which includes that information, or provide further support
    (other than BVI law) for any material items you continue to omit.

Response:
In response to the Staff’s comment, we hereby attach, as Exhibit A hereto, proposed changes to the Proxy Statement (beginning
on page 120) to provide additional disclosure relating to the projections prepared by NESR’s management in connection
with the initial business combination. For your convenience, a redline showing changes from our April 23, 2018 filing has
been attached as Exhibit B hereto.

In
particular, we have tried to provide helpful information on the projections. The proposed additional disclosure has now
been expanded to include five-year projections (in addition to 2017) as well as analysis to arrive at projected Unlevered
cash flow projections, the summary of which has been provided in Exhibit A attached hereto. In response to the Staff’s
comment, although NESR’s board of directors did not consider segment or geographical information in evaluating
the initial business combination, we have expanded our disclosures to include revenue growth projections by segment on a
combined basis, which are in line with the reporting segments of major international oilfield service
providers.

We
thank the Staff for its review of the foregoing. If you have any questions relating to the foregoing or further comments, please
contact our counsel, Benjamin Reichel, at breichel@egsllp.com or by telephone at (212) 370-1300.

    Very
    truly yours,

    /s/
    Sherif Foda

    Sherif
    Foda, Chief Executive Officer

cc: Ellenoff
Grossman & Schole LLP

Exhibit
A

Proposed
Changes (Clean)

Certain
Unaudited Internal Financial Projections

Management
of NESR prepared prospective financial information to assist NESR’s Board of Directors in evaluating the NPS and GES operations
and prospects and the potential acquisitions and to J.P. Morgan to be used for purposes of its financial analyses in connection
with its written opinion. The accompanying summary unaudited internal financial projections of NPS and GES were not prepared with
a view toward public disclosure or with a view toward complying with the guidelines established by the American Institute of Certified
Public Accountants with respect to prospective financial information. In the view of the management of NESR, NPS and GES, the
financial projections were prepared on a reasonable basis, reflected the best currently available estimates and judgments of NPS
and GES, as applicable, and presented, to the best of their knowledge and belief, the expected course of action and the expected
future financial performance of NPS and GES, respectively. However, the financial projections are not fact. Additionally, not
all of the prospective financial information prepared by NESR’s management and included below were used by NESR’s
Board of Directors in evaluating the Target Companies. Further, none of the unaudited internal financial projections reflect any
impact of the proposed transaction and have not been updated since the date of preparation.

None
of NESR’s, NPS’s or GES’s independent auditors, nor any other independent auditors, nor any of their financial
advisors, have compiled, examined or performed any procedures with respect to the unaudited internal financial projections contained
herein, nor have they expressed any opinion or any other form of assurance on such information or its achievability, and assume
no responsibility for the financial projections. The reports of the independent registered public accounting firms included in
this proxy statement or incorporated by reference relate to the historical financial information of NESR, NPS and GES, respectively.
Such reports do not extend to the unaudited financial projections and should not be read to do so.

The
unaudited financial projections set forth below were prepared by NESR’s management based on information available to them,
in particular with respect to each of the Target Companies. The unaudited financial projections were prepared based on reviews
of financial information about GES and NPS provided to NESR during due diligence and negotiations. These documents included market
analysis, projections for the various regions and product lines, growth plans and market share estimates for large service companies
and smaller service providers and all were prepared by GES, NPS and NESR. These included extensive discussions between NESR’s
management with each of GES’s management and stockholders and NPS’s management and stockholders, and NESR’s
management’s knowledge of the industries in which the companies operate. In connection with the negotiation of the definitive
agreements providing for the transaction and prior to the preparation of the unaudited financial projections, NESR negotiated
with the NPS Selling Stockholders certain EBITDA-based earnouts, which were based in part on preliminary projections for the performance
of NPS.

In
developing the unaudited financial projections set forth below, NESR, NPS and GES assumed crude oil and natural gas prices remained
consistent with current levels and that activity levels in operating areas for NPS and GES would continue to grow even in a cyclic
crude oil price environment. The projections included growth in the overall market for similar services provided by NPS and GES
of 4%, market share and pricing for 2017 – 2019 were projected to remain constant and synergies were projected to be achieved
as discussed in Projected Synergies. Overall cumulatively for the combined companies for the period of 2017 to 2022, revenue Compound
Annual Growth Rate (“CAGR”) for Production Services segment was projected to be 13.8% and for Drilling & Evaluation
Services was projected to be 15% for a total CAGR of 14.2%.

    Year
    Ending December 31,

    Revenue
    by Segment for NPS and GES combined
    2017E
    2018E
    2019E
    2020E
    2021E
    2022E

    ($
    in millions)

    Drilling
    & Evaluation Services
    $ 152
    $ 203
    $ 228
    $ 257
    $ 279
    $ 306

    Production
    Services
    $ 289
    $ 309
    $ 393
    $ 452
    $ 504
    $ 551

    Total
      441
      512
      621
      709
      783
      857

The
unaudited internal financial projections were prepared solely for internal use to assist in the evaluation of the business combination.
Such projections are inherently subjective in nature, though considered reasonable by the management of NESR, NPS and GES, as
of the date such projections were prepared, and are susceptible to interpretation and, accordingly, contemplated results may not
be achieved. While presented with numerical specificity, the unaudited internal financial projections reflect numerous estimates
and assumptions with respect to future industry performance under various industry scenarios as well as assumptions for competition,
general business, economic, market and financial conditions and matters specific to the businesses of NESR, NPS and GES, all of
which are difficult to predict and many of which are beyond the preparing parties’ control including, among other things,
the matters described in the sections entitled “Cautionary Note Regarding Forward-Looking Statements” and “Risk
Factors.” Accordingly, there can be no assurance that the assumptions made in preparing any particular projection will prove
accurate. There will be differences between actual and forecasted results, and the differences may be material. The risk that
these uncertainties and contingencies could cause the assumptions to fail to be reflective of actual results is further increased
due to the length of time over which these assumptions apply. While the NESR Board of Directors used the following projections
as a tool in evaluating the Business Combination, they did so with a thorough understanding of the foregoing limitations. In light
of the foregoing factors and the uncertainties inherent in the unaudited internal financial projections, the NESR shareholders
are cautioned not to place undue reliance on the unaudited internal financial projections and the inclusion of the unaudited internal
financial projections in this proxy statement should not be regarded as a representation by any person that the results contained
therein will be achieved.

The
unaudited internal financial projections are not included in this proxy statement in order to induce any NESR shareholders to
vote in favor of any of the proposals at the NESR special meeting in lieu of an annual meeting.

Certain
of the measures included in the unaudited internal financial projections are non-GAAP financial measures, as noted below. Non-GAAP
financial measures should not be considered in isolation from, or as a substitute for, financial information presented in compliance
with GAAP, and non-GAAP financial measures as used by NESR, NPS and GES are not reported by all of their competitors and may not
be comparable to similarly titled amounts used by other companies. We encourage you to review the financial statements of NPS
and GES included in this proxy statement, as well as the financial information in the sections entitled “Selected Historical
Financial Information of NPS,” “Selected Historical Financial Information of GES” and “Unaudited Pro Forma
Condensed Consolidated Combined Financial Information” in this proxy statement and to not rely on any single financial measure.

Except
as required by federal securities laws, NPS and GES do not intend to update or otherwise revise the unaudited internal financial
projections to reflect circumstances existing after the date they were made or to reflect the occurrence of future events, even
in the event that any or all of the assumptions underlying such unaudited financial projections are no longer appropriate.

NPS
Projections

    Year
    Ending December 31,

    2017E
     2018E
    2019E
     2020E
    2021E
     2022E

    ($
    in millions)

    Revenue
    $ 246
    $ 290
    $ 340
    $ 391
    $ 424
    $ 448

    EBITDA(1)
    $ 84
    $ 100
    $ 119
    $ 137
    $ 147
    $ 153

    Capital
    Expenditures
    $ 39
    $ 33
    $ 35
    $ 35
    $ 35
    $ 35

    Unlevered
    Free Cash Flow (2)
    $ 16
    $ 34
    $ 50
    $ 73
    $ 86
    $ 105

    (1)
    NPS
    defines EBITDA as net income (loss) before interest expense, income taxes and depreciation and amortization. See “Selected
    Historical Financial Information of NPS” and “Non-GAAP Financial Measures”

    (2)
    Unlevered
    Free Cash Flow is a non-GAAP financial measure and should not be considered as an alternative to operating income or net income
    as a measure of operating performance or cash flows or as a measure of liquidity. Unlevered free cash flow, as defined above,
    is defined as EBITDA (as defined above) less income tax, less (increase) decrease in net working capital and less capital
    expenditure.

    Reconciliation
    of Unleavered Free Cash Flow
      2017E
      2018E
      2019E
      2020E
      2021E
      2022E

      ($
                                         in millions)

    EBITDA
    $ 84
    $ 100
    $ 119
    $ 137
    $ 147
    $ 153

    Taxes
    $ (6 )
    $ (8 )
    $ (11 )
    $ (13 )
    $ (15 )
    $ (16 )

    Capex
    $ (39 )
    $ (33 )
    $ (35 )
    $ (35 )
    $ (35 )
    $ (35 )

    Change
    in Working Capital
    $ (23 )
    $ (25 )
    $ (23 )
    $ (16 )
    $ (11 )
    $ 3

    Unlevered
    Free Cash Flow
    $ 16
    $ 34
    $ 50
    $ 73
    $ 86
    $ 105

GES
Projections

    Year
    Ending December 31,

    2017E
    2018E
    2019E
    2020E
    2021E
    2022E

    ($
    in millions)

    Revenue
    $ 195
    $ 222
    $ 281
    $ 318
    $ 359
    $ 409

    EBITDA(1)
    $ 71
    $ 74
    $ 95
    $ 108
    $ 122
    $ 138

    Capital
    Expenditures
    $ 13
    $ 40
    $ 25
    $ 25
    $ 25
    $ 25

    Unlevered
    Free Cash Flow (2)
    $ 69
    $ 18
    $ 40
    $ 60
    $ 72
    $ 82

    (1)
    GES
    defines EBITDA as net income (loss) before interest expense, income taxes, depreciation and amortization. See “Selected
    Historical Financial Information of GES” and “Non-GAAP Financial Measures”

    (2)

    Unlevered
    Free Cash Flow is a non-GAAP financial measure and should not be considered as an alternative to operating income or net income
    as a measure of operating performance or cash flows or as a measure of liquidity. Unlevered free cash flow, as defined above,
    is defined as EBITDA (as defined above) less income tax, less (increase) decrease in net working capital and less capital
    expenditure.

    Reconciliation
    of Unleavered Free Cash Flow
      2017E
      2018E
      2019E
      2020E
      2021E
      2022E

      ($
                                         in millions)

    EBITDA
    $ 71
    $ 74
    $ 95
    $ 108
    $ 122
    $ 138

    Taxes
    $ (6 )
    $ (6 )
    $ (9 )
    $ (10 )
    $ (11 )
    $ (13 )

    Capex
    $ (13 )
    $ (40 )
    $ (25 )
    $ (25 )
    $ (25 )
    $ (25 )

    Change
    in Working Capital
    $ 17
    $ (10 )
    $ (21 )
    $ (13 )
    $ (14 )
    $ (18 )

    Unlevered
    Free Cash Flow
    $ 69
    $ 18
    $ 40
    $ 60
    $ 72
      82

Projected
Synergies

The
expected cost savings and synergies include NESR’s estimates of spare equipment available for deployment and incremental
activity that NESR believes they can bring to the Target Companies by utilizing existing equipment as well as additional investments
in new technology and tools to generate incremental revenue, EBITDA and net income. The expected synergies also include the cross-utilization
of services and equipment from one Target Company to the other Target Company rather than utilizing services of a third party.
The cost savings also include savings from integrating the two organizations under one company resulting from efficiencies in
information systems, support functions, supply chain and other infrastructure restructuring. These synergies and cost savings
were net of additional costs incurred by NESR to meet its more complex reporting and internal control requirements as a public
company. For the period 2018-2022, EBITDA synergies are estimated to be $25 million, $33 million, $53 million. $79 million,
$95 million and $97 million for each consecutive twelve (12) month period after Business Combination. These EBITDA synergies
are not reflected in the projections provided above.