Pacific Drilling S.A.
8-10, Avenue de la Gare
L-1610 Luxembourg
ph / 00 352 278 58 139 Fax / 00 352 278 58 140
web / www.pacificdrilling.com
December 26, 2018
VIA EDGAR SUBMISSION
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Kevin Dougherty
| Re: | Pacific Drilling S.A. |
Registration Statement on Form F-1 (Registration No. 333-228867) |
Request for Acceleration |
Ladies and Gentlemen:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned registration statement on Form F-1 (the “Registration Statement”) relating to the registration of 54,762,877 common shares, par value $0.01, of Pacific Drilling S.A. (the “Company”), be accelerated to December 26, 2018 at 4:00 p.m. E.S.T. or as soon thereafter as may be practicable. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Jones Walker LLP, by calling Dionne M. Rousseau at (504) 582-8191.
We understand that the staff of the Securities and Exchange Commission will consider this request as confirmation by the Company that it is aware of its responsibilities under the federal securities laws as they relate to the registration and sale of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Dionne M. Rousseau at the number set forth above. Thank you for your assistance in this matter.
| Sincerely, | ||||
| /s/ Lisa Manget Buchanan | |||
| By: | Lisa Manget Buchanan | |||
| Title: | SVP, General Counsel & Secretary | |||
| cc: | Dionne M. Rousseau, Jones Walker LLP |