Valaris Limited
Clarendon House, 2 Church Street
Hamilton, Bermuda HM 11
44 (0) 20 7659 4660
July 15, 2021
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Re: | Valaris Limited Registration Statement on Form S-1 File No. 333-257022 |
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned, Valaris Limited, a Bermuda exempted company, on behalf of itself and each of the co-registrant subsidiary guarantors, hereby respectfully requests acceleration of the effective date of its Registration Statement on Form S-1, File No. 333-257022, as amended (the “Registration Statement”), so that it may become effective at 5:00 p.m., Eastern Time, on July 19, 2021, or as soon thereafter as practicable.
Please contact Julian J. Seiguer, P.C. and Michael W. Rigdon of Kirkland & Ellis LLP at (713) 836-3334 and (713) 836-3647, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
Sincerely, | ||
Valaris Limited | ||
By: | /s/ Jonathan H. Baksht | |
Name: | Jonathan H. Baksht | |
Title: | Executive Vice President and Chief Financial Officer | |
cc: | Julian J. Seiguer, P.C., Kirkland & Ellis LLP | |
Michael W. Ridgon, Kirkland & Ellis LLP |
2