October 8, 2019

James Reddinger
President and Chief Executive Officer
Stabilis Energy, Inc.
10375 Richmond Avenue, Suite 700
Houston, Texas 77042

       Re: Stabilis Energy, Inc.
           Registration Statement on Form S-1
           Filed September 11, 2019
           File No. 333-233704

Dear Mr. Reddinger:

       We have reviewed your registration statement and have the following
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 filed September 11, 2019

Index to Financial Statements
Audited Consolidated Financial Statements for the Years Ended December 31, 2018
and 2017
Notes to Consolidated Financial Statements
(2) Revenue Recognition, page F-12

1.     Please address the following comments related to your revenue
recognition accounting
       policies:

           We note your disclosure at the bottom of page 56 that you have
contracts with
           multiple trucking companies that deliver LNG to customers. Tell us
and disclose
           whether you record revenues associated with third party deliveries
gross as a
           principal or net as an agent. Explain how you considered the
guidance in ASC 606-
 James Reddinger
FirstName LastNameJames Reddinger
Stabilis Energy, Inc.
Comapany 2019
October 8, NameStabilis Energy, Inc.
October 8, 2019 Page 2
Page 2
FirstName LastName
              10-55-37 through 39 in arriving at your determination. Also tell
us how, if at all,
              your accounting policy changes for LNG produced at your
liquefaction plant versus
              LNG purchased from third parties.

              We note that you reference "performance obligations" associated
with your rental
              revenues. Tell us if your rental activities are within the scope
of ASC 606 or ASC
              840/842. If your rental activities are not within the lease
accounting scope, explain in
              sufficient detail how you arrived at such conclusion. See ASC
840-10-15 and 842-
              10-15.
(3) Step Acquisition of Equity Interests, page F-13

2.       We note the $13.9 million bargain purchase gain recorded for the step
acquisition of
         Stabilis LNG Eagle Ford, LLC ("LNG EF") and Stabilis FHR Oilfield LNG,
LLC
         ("FHR") in 2017. Please confirm that this gain was recognized as a
result of applying
         ASC 805-10-25-9 and 10 or, alternatively, tell us the authoritative
GAAP guidance you
         followed. We also note that you revalued your retained 50% investment
in LNG EF at
         $17.9 million as of the acquisition date. Considering you acquired the
remaining 50%
         interest for $4 million, explain to us in sufficient detail how you
determined the $17.9
         million fair value, clarify why you believe that valuation is
reasonable, and reconcile for
         us the significant valuation difference between the retained and newly
acquired 50%
         interests.
(4) Acquisition of PEG Partners, LLC, page F-14

3.       You disclose that you accounted for the acquisition of PEG Partners,
LLC ("PEG") "as a
         combination of entities under common control and consolidated all
assets and liabilities
         assumed at historical costs as of the acquisition date." However, you
also present a
         purchase price allocation with estimated fair values and disclose that
the bargain purchase
         gain "represents the difference between the fair value of the net
assets acquired over the
         cash paid." Please tell us your basis in GAAP for performing a fair
value assessment
         related to this common control transaction and for recording a bargain
purchase gain.
         Please be specific when citing the authoritative guidance you relied
on for your
         accounting.
General

4.       You disclose that you effectuated a 1:8 reverse stock split of your
outstanding common
         stock during the third quarter of fiscal 2019. When you disclose the
number of shares
         AETI issued in the Share Exchange, please ensure that the number of
shares issued is
         consistent throughout your document or present both numbers and
affirmatively identify
         the pre-split and post-split figures. For example, you disclose on
page 2 that 105,558,606
         shares were issued but disclose on page 76 that 13,194,825 shares were
issued.
 James Reddinger
Stabilis Energy, Inc.
October 8, 2019
Page 3

        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.

       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.

       You may contact Yong Kim, Staff Accountant at 202-551-3323 or Andrew
Blume, Staff
Accountant at 202-551-3254 if you have questions regarding comments on the
financial
statements and related matters.



FirstName LastNameJames Reddinger                          Sincerely,
Comapany NameStabilis Energy, Inc.
                                                           Division of
Corporation Finance
October 8, 2019 Page 3                                     Office of Trade &
Services
FirstName LastName