March 27, 2018
Via EDGAR transmission
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549-7010
Attn: Pamela A. Long
| Re: | Request for Acceleration of Effectiveness of McDermott International, Inc. and Comet I B.V.’s Registration Statement on Form S-4 (File No. 333-222662). |
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, McDermott International, Inc. and Comet I B.V. (the “Registrants”) hereby request that the effectiveness of the Registration Statement on Form S-4 (File No. 333-222662) (as amended to date, the “Registration Statement”) be accelerated so that the Registration Statement will become effective on March 29, 2018, at 2:00 p.m. Eastern time, or as soon thereafter as practicable.
Please call Ted W. Paris or Mark Gordon at (713) 229-1838 or (212) 403-1343, respectively, if you have any questions regarding this request, and please notify either of them when this request for acceleration has been granted.
| Sincerely, | ||
| McDermott International, Inc. | ||
| By: | /s/ David Dickson | |
| David Dickson | ||
| President and Chief Executive Officer | ||
| Comet I B.V. | ||
| By: | /s/ Michael S. Taff | |
| Michael S. Taff | ||
| Managing Director | ||
| cc: | Ted W. Paris |
Baker Botts L.L.P.
| Mark Gordon |
Wachtell, Lipton, Rosen & Katz
