[Forbes Letterhead]
August 10, 2011
The Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. H. Roger Schwall:
| Re: | Registration Statement on Form S-4, as amended, under the Securities Act of 1933, as amended (Registration No. 333-170741), filed by Forbes Energy Services Ltd. |
Dear Mr. Schwall:
Forbes Energy Services Ltd. (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement be accelerated so that such Registration Statement becomes effective at 5:15 p.m., Washington, D.C. time, on August 11, 2011, or as soon thereafter as is practicable. In connection with the Company’s acceleration request, the Company acknowledges that:
1. should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
2. the action of the Commission or the staff, 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
3. the Company may not assert staff comments 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.
Please contact R. Clyde Parker, Jr. at (281) 681-5930 once the Registration Statement is declared effective.
| | |
FORBES ENERGY SERVICES LTD. |
| |
By: | | /s/ L. Melvin Cooper |
| | L. Melvin Cooper |
| | Executive Vice President, Chief Financial Officer and Assistant Secretary |