Correspondence 0001193125-23-084837 from Seadrill Ltd (SDRL) (CIK 0001737706) (SDRL)
Seadrill Ltd (SDRL) (CIK 0001737706)
Date: March 30, 2023 · CIK: 0001737706 · Accession: 0001193125-23-084837
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File numbers found in text: 333-270071
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CORRESP 1 filename1.htm Acceleration Request SEADRILL LIMITED 55 Par-la-Ville Road Hamilton, HM 11 Bermuda +1 (441) 295-9500 March 30, 2023 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Claudia Rios Office of Energy & Transportation Re: Request for Acceleration of Effectiveness of Seadrill Limited’s Registration Statement on Form F-4 (File No. 333-270071) initially filed on February 27, 2023, as amended by Amendment No. 1 thereto filed on March 23, 2023 and Amendment No. 2 thereto filed on March 29, 2023. Dear Ms. Rios: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Seadrill Limited hereby requests that the effectiveness of the Registration Statement on Form F-4 (File No. 333-270071) (the “Registration Statement”) be accelerated so that the Registration Statement will become effective on March 31, 2023 at 4:00 p.m., Eastern Daylight Time, or as soon thereafter as practicable. Please call David Emmons or Clinton W. Rancher of Baker Botts L.L.P. at (214) 953-6414 or (713) 229-1820, respectively, if you have any questions regarding this request, and please notify either of them when this request for acceleration has been granted. [Signature on following page] Very truly yours, SEADRILL LIMITED By: /s/ Todd Strickler Todd Strickler Senior Vice President and General Counsel cc: David Emmons, Baker Botts L.L.P. Clinton W. Rancher, Baker Botts L.L.P. David P. Elder, Akin Gump Strauss Hauer & Feld LLP Patrick Hurley, Akin Gump Strauss Hauer & Feld LLP