September 28, 2018 Jay A. Nudi Chief Financial Officer ODYSSEY MARINE EXPLORATION INC 5215 W. Laurel Street Tampa, Florida 33607 Re: Odyssey Marine Exploration Inc Form 10-K for the year ended December 31, 2017 Filed on March 26, 2018 File No. 001-31895 Dear Mr. Nudi: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Transportation and Leisure