CORRESP 1 filename1.htm

 

[Global Geophysical Services, Inc. Letterhead]

 

April 21, 2010

 

Via Edgar and Facsimile (703) 813-6982

 

Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C.  20549

Attn:  John P. Lucas

 

Re:          Global Geophysical Services, Inc.

Registration Statement on Form S-1

File No. 333-162540

 

Ladies and Gentlemen:

 

Global Geophysical Services, Inc. (the “Company”) requests that the effective date of the above-captioned Registration Statement be accelerated so that such Registration Statement will be declared effective at 4:00 p.m., Washington, D.C. time, on Wednesday, April 21, 2010, or as soon as practicable thereafter.

 

The Company hereby acknowledges that:

 

·                  should the Securities and Exchange Commission (“Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 

·                  the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 

·                 the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

 

Very truly yours,

 

 

 

 

 

/s/ Alvin L. Thomas II

 

Alvin L. Thomas II

 

Senior Vice President & General Counsel