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                   November 17, 2020

       Philip A. Choyce
       Executive Vice President and Chief Financial Officer
       Independence Contract Drilling, Inc.
       20475 State Highway 249, Suite 300
       Houston, TX 77070

                                                        Re: Independence
Contract Drilling, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed November 13,
2020
                                                            File No. 333-250092

       Dear Mr. Choyce :

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

              Please contact Irene Barberena-Meissner, Staff Attorney, at
202-551-6548 with any
       questions.




                   Sincerely,


                   Division of Corporation Finance

                   Office of Energy & Transportation
       cc:                                              David C. Buck, Esq.