December 18, 2018
VIA EDGAR
Kevin Dougherty
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E. Mail Stop 4628
Washington, D.C. 20549-3561
| Re: | SAExploration Holdings, Inc. |
Registration Statement on Form S-3
File No. 333-228738
Dear Mr. Dougherty:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, SAExploration Holdings, Inc. (the “Company”) hereby requests acceleration of the effective date of the above referenced Registration Statement on Form S-3 to December 20, 2018 at 4:00 p.m., Eastern time, or as soon as practicable thereafter.
The Company authorizes each of Chris Centrich and Eric Muñoz, each of whom is associated with the Company’s outside counsel, Akin Gump Strauss Hauer & Feld LLP, to orally modify or withdraw this request for acceleration.
Kevin Dougherty
U.S. Securities and Exchange Commission
If you have any questions, or require any additional information, please do not hesitate to call me at (281) 258-4400 or Chris Centrich of Akin Gump Strauss Hauer & Feld LLP at (713) 220-8143.
| Very truly yours, | ||
| SAEXPLORATION HOLDINGS, INC. | ||
By: | /s/ Brent Whiteley | |
Brent Whiteley Chief Financial Officer, General Counsel and Secretary | ||
| cc: | Ryan Abney, SAExploration Holdings, Inc. |
Chris Centrich, Akin Gump Strauss Hauer & Feld LLP
Eric Muñoz, Akin Gump Strauss Hauer & Feld LLP