STONE ENERGY CORPORATION
625 E. Kaliste Saloom Road
Lafayette, Louisiana 70508
VIA EDGAR
February 24, 2017
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Parhaum J. Hamidi
| Re: | Stone Energy Corporation |
| FormT-3 (FileNo. 022-29034) |
Ladies and Gentlemen:
We refer to the Application for Qualification of Indenture on FormT-3 (FileNo. 022-29034) (as amended, the “FormT-3”) of Stone Energy Corporation (the “Company”), initially filed on November 17, 2016 with the Securities and Exchange Commission (the “Commission”), in connection with the qualification under the Trust Indenture Act of 1939, as amended (the “Act”), of the indenture governing the Company’s new 7.500% Senior Secured Notes due 2022.
On February 24, 2017, the Company filed Amendment No. 4 to the above referenced FormT-3. In accordance with Section 307(c) of the Act, we hereby respectfully request the acceleration of the effectiveness of the above referenced FormT-3 so that it may become effective at or prior to 3:00 p.m. (Eastern time) on February 27, 2017 or as soon as reasonably practicable thereafter.
In connection with the filing of the FormT-3, the Company hereby acknowledges that:
| • | should the Commission or the Staff of the Division of Corporation Finance of the Commission (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; |
| • | 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 |
| • | 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 John M. Greer of Latham & Watkins LLP at(713) 546-7472 to confirm the effectiveness of the FormT-3.
| STONE ENERGY CORPORATION | ||||
| By: | /s/ Kenneth H. Beer | |||
| Name: | Kenneth H. Beer | |||
| Title: | Executive Vice President and Chief Financial Officer | |||
