September 8, 2005

Mr. Jonathan Miller
President and Chief Executive Officer
General Geophysics Company
CT Corporation System
111 Eighth Avenue
New York, New York 10011

Re:	General Geophysics Company
		Registration Statement on Forms F-4 and S-4
      Filed July 13, 2005
	File No. 333-126553

	Annual Report on Form 20-F for the year ended December 31,
2004
	Filed April 18, 2005
	File No. 01-14622

Dear Mr. Miller:

      We have limited our review of the above filings and your
supplemental draft response letter dated September 1, 2005 to only
the
areas upon which we have issued comments.  Where indicated, we
think
you should revise your documents in response to these comments.
If
you disagree, we will consider your explanation as to why our
comment
is inapplicable or a revision is unnecessary.  Please be as
detailed
as necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
raise additional comments.

Forms F-4 and S-4 and Form 20-F for the Year Ended December 31,
2004

Operating and Financial Review and Prospects, page 29

Liquidity and Capital Resources, page 39

1. We have read your response to prior comment 2, explaining that
you
wish to present your non-GAAP measure of Operating Results Before
Depreciation and Amortization because it represents a factor
necessary
to calculate a ratio identified as a debt covenant item.  Given
this
representation, it is unclear why you have not also shown the
ratio
that you believe is of such importance, and included discussion of
the
extent of your compliance with the covenant.

Financial Statements

Note 1 - Summary of Significant Accounting Policies, page F-7

Multi-Client Survey Accounting, page F-8

Revenue Recognition

2. We note your response to prior comment 5, in which you explain
that
you "must reconsider the final payment to be received from the
customer if certain milestones are not met," while further
clarifying
in your draft disclosure revision, that under such circumstances,
"...the Company reduces its revenues accordingly."  For U.S. GAAP
purposes, the guidance in SAB Topic 13:A, paragraphs 3(b) and
4(a),
imposes limitations on revenue recognition when customer
acceptance
has not been received, or when the sales price is not fixed or
determinable, as is generally believed to be the case during
periods
in which the customer has a right to cancel the transaction and
receive a cash refund.  This guidance further explains that
"...revenue should not be recognized in earnings by assessing the
probability that significant but unfulfilled terms of a contract
will
be fulfilled at some point in the future."

Please elaborate on the meaning of your phrases "must reconsider"
and
"may be bound to reconsider," as they relate to circumstances in
which
milestones are established by contractual arrangement; and
describe
the manner by which you would reduce your revenues to comply with
your
contractual obligations, governing the provision of services.
Tell us
why you believe the guidance in SAB Topic 13 would not require the
deferral of revenue recognition on contracts including customer
acceptance provisions, or extending a right of cancellation to
customers, until acceptance has occurred or the rights of
cancellation
have lapsed, for U.S. GAAP purposes, if that is your view.

Closing Comments

      As appropriate, please amend the above filings in response
to
these comments.  You may wish to provide us with a marked copy of
the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities Act of 1933
and
that they have provided all information investors require for an
informed investment decision.  Since the company and its
management
are in possession of all facts relating to a company`s disclosure,
they are responsible for the accuracy and adequacy of the
disclosures
they have made.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please contact John Weitzel at (202) 551-3731 or Karl
Hiller,
Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the financial statements and related matters.  Please
contact Jason Wynn at (202) 551-3756 or me at (202) 551-3740 with
any
other questions.  Direct all correspondence to the following ZIP
code:
20549-7010.

									Sincerely,


									H. Roger Schwall
									Assistant Director


      cc:  J. Wynn
            J. Weitzel
      K. Hiller

            via facsimile
      Thomas N. O`Neill III and Luis Roth
            Linklaters
            011 33 1 4359 4196
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Mr. Jonathan Miller
General Geophysics Company
September 8, 2005
page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE
         MAIL STOP 7010