November 7, 2018

John T. Rynd
President and Chief Executive Officer
Tidewater Inc.
6002 Rogerdale Road
Suite 600
Houston, TX 77072

       Re: Tidewater Inc.
           Registration Statement on Form S-1
           Filed October 29, 2018
           File No. 333-228029

Dear Mr. Rynd:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-1

General

1.     Please include, or incorporate by reference to the extent you are
eligible, the financial
       statements of GulfMark Offshore, Inc., along with the related pro forma
financial
       statements, for the periods required by Article 8-04 to Regulation S-X.
        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.
 John T. Rynd
Tidewater Inc.
November 7, 2018
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact J. Nolan McWilliams, Attorney-Advisor, at (202) 551-3217
or Laura
Nicholson, Special Counsel, at (202) 551-3584 with any questions you may have.



                                                           Sincerely,
FirstName LastNameJohn T. Rynd
                                                           Division of
Corporation Finance
Comapany NameTidewater Inc.
                                                           Office of
Transportation and Leisure
November 7, 2018 Page 2
cc:       Hope Spencer
FirstName LastName