ENERGY XXI (BERMUDA) LIMITED
Canon’s Court, 22 Victoria Street, PO Box HM 1179
Hamilton HM EX, Bermuda
March 14, 2008
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 7010
Washington, D.C. 20549-7010
Attention: Laura Nicholson
| | Re: | Request for Acceleration of Effectiveness of Registration Statement on Form S-3 (Registration No. 333-148713) (the “Registration Statement”) of Energy XXI (Bermuda) Limited, a Bermuda corporation (the “Company”) |
Ladies and Gentlemen:
Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of 1933, as amended, the Company hereby requests that the effectiveness of the above-referenced Registration Statement as originally filed by the Company on January 17, 2008 be accelerated so that the Registration Statement will become effective on Tuesday, March 18, 2008 at 4:00 p.m., New York time, or as soon as thereafter practicable. The Company hereby acknowledges that:
| · | should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| · | the action of the Commission or the staff of the Commission, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| · | the Company may not assert comments of the staff of the Commission and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Securities and Exchange Commission
March 14, 2008
Very truly yours,
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| | ENERGY XXI (BERMUDA) LIMITED |
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| | By: | /s/ David West Griffin |
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David West Griffin Chief Financial Officer |
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