April 28, 2014

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: William H. Thompson, Accounting Branch Chief

Re: MarineMax, Inc.

Form 10-K for the Fiscal Year Ended September 30, 2013

Filed December 6, 2013

File No. 001-14173

Dear Mr. Thompson:

On behalf of MarineMax, Inc. (“MarineMax”), I am writing in response to certain telephone conversations over the past few days between Scott Stringer, Staff Accountant, and our counsel at Holland & Knight LLP.

My understanding is that, to assist the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) in its evaluation of the response of MarineMax dated April 4, 2014, the Staff asked that MarineMax provide certain additional information. Specifically, the Staff asked that MarineMax provide cost of sales and gross profit calculations for its products and services under two alternatives: (1) with brokerage reflected in the “Products and Rentals” line item and (2) with brokerage reflected in the “Service” line item. These calculations are presented below.

The below table reflects brokerage in the “Products and Rentals” line items.

	2011		2012		2013
Revenue:
Products and Rentals		438,508		479,791		537,045
Service		42,386		44,665		47,452
Total Revenue		480,894		524,456		584,497
Cost of Sales:
Products and Rentals		344,423		374,213		416,488
Service		16,977		16,960		17,156
Total Cost of Sales		361,400		391,173		433,644
Gross Profit:
Products and Rentals		94,085		105,578		120,557
Service		25,409		27,705		30,296
Total Gross Profit		119,494		133,283		150,853

Securities and Exchange Commission

April 28, 2014

Page 2 of 3

The below table reflects brokerage in the “Service” line items.

	2011		2012		2013
Revenue:
Products and Rentals		425,951		467,488		523,230
Service		54,943		56,968		61,267
Total Revenue		480,894		524,456		584,497
Cost of Sales:
Products and Rentals		344,423		374,213		416,488
Service		16,977		16,960		17,156
Total Cost of Sales		361,400		391,173		433,644
Gross Profit:
Products and Rentals		81,528		93,275		106,742
Service		37,966		40,008		44,111
Total Gross Profit		119,494		133,283		150,853

Finally, as the Staff considers this information, MarineMax believes it is worth noting that as its industry recovers and boat sales rise (trends MarineMax believes are consistent with recent facts), MarineMax believes the services revenue of MarineMax over the next few years will very likely be less than 10% of its total revenue regardless of how brokerage is classified.

*        *        *

MarineMax acknowledges the following:

• MarineMax is responsible for the adequacy and accuracy of the disclosure in its Commission filings;

• Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

• MarineMax may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

MarineMax believes that the foregoing responds fully to Mr. Stringer’s verbal requests. Please let us know if you have any questions about our responses.

Securities and Exchange Commission

April 28, 2014

Page 3 of 3

Respectfully submitted,
MarineMax, Inc.
By:	/s/ Michael H. McLamb
	Michael H. McLamb
	Chief Financial Officer

cc: William H. McGill, Jr., Chief Executive Officer, MarineMax, Inc.

Paulee Day, General Counsel, MarineMax, Inc.

Robert J. Grammig, Esq., Holland & Knight LLP

Steven W. McMullen, Partner, KPMG LLP