Seadrill Limited
Par-la-Ville Place, 4th Floor
14Par-la-Ville Road
Hamilton HM 08, Bermuda
August 20, 2018
Via EDGAR Submission
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: John Reynolds
Mail Stop 4628
Re: | Seadrill Limited (formerly known as New SDRL Limited) |
Registration Statement on FormF-1 (FileNo. 333-224459) |
Request for Acceleration |
Dear Mr. Reynolds:
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 FormF-1 (the “Registration Statement”) relating to the registration of 76,359,119 common shares, par value $0.10, of Seadrill Limited (the “Company”), be accelerated to August 21, 2018 at 4:00 p.m. E.D.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, Kirkland & Ellis LLP, by calling Wayne E. Williams at (312)862-7135.
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 Wayne E. Williams of Kirkland & Ellis at the number set forth above. Thank you for your assistance in this matter.
Sincerely, | ||||||
/s/ Georgina Sousa | ||||||
Georgina Sousa | ||||||
Secretary |
cc: | Dennis M. Myers, Kirkland & Ellis LLP |
Wayne E. Williams, Kirkland & Ellis LLP |