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                           June 17, 2021

       Jonathan H. Baksht
       Executive Vice President and Chief Financial Officer
       Valaris Ltd
       Clarendon House, 2 Church Street
       Hamilton, Bermuda, HM 11

                                                        Re: Valaris Ltd
                                                            Registration
Statement on Form S-1
                                                            Filed June 11, 2021
                                                            File No. 333-257022

       Dear Mr. Baksht:

              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 Liz
Packebusch, Staff Attorney, at (202) 551-8749 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Energy & Transportation
       cc:                                              Michael Rigdon