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| Key Energy Services, Inc. 1301 McKinney Suite 1800 Houston, Texas 77010 | Telephone: 713.651.4300 Facsimile: 713.652.4005 www.keyenergy.com
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October 26, 2006
Mr. Jon Duersch
Securities and Exchange Commission
100 F Street, N.W., Stop 7010
Washington, D.C. 20549
Re: Item 4.02 Form 8-K
Filed October 20, 2006
File No. 1-08038
Dear Mr. Duersch:
Key Energy Services, Inc. (the “Company”) is filing with the Securities and Exchange Commission (the “Commission”) Amendment No. 1 to the Company’s Current Report on Form 8-K (File No. 1-08038) filed with Commission on October 19, 2006 (the “Form 8-K”). This letter responds to the Commission’s letter dated October 20, 2006 transmitting the Commission’s comments with respect to Item 4.02 to the Form 8-K. Please note that the Form 8-K has been amended to provide the information required by Item 4.02(a) of Form 8-K as specified in your letter.
If you have any questions or comments regarding the Form 8-K, as amended, please call me at 713-651-4412 or Kimberly Frye, Associate General Counsel, at 713-651-4444.
| Sincerely, |
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| /s/ Newton W. Wilson III | |
| Newton W. Wilson III |
| Senior Vice President and |
| General Counsel |
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NWWIII/ca |
|
Enclosure |