CORRESP 1 filename1.htm State Street Bank and Trust Company

282370082v.3

Independence Contract Drilling, Inc.

20475 State Highway 249, Suite 300

Houston, Texas 77070

June 15, 2022

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Cheryl Brown and Karina Dorin

Re:

Independence Contract Drilling, Inc.

Registration Statement on Form S-3

Filed June 9, 2022

File No. 333-264286

Dear Ms. Brown and Ms. Dorin:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Independence Contract Drilling, Inc. hereby respectfully requests that the effective date of the above-referenced Registration Statement be accelerated to Friday, June 17, 2022 at 4:00 p.m. (Eastern time) or as soon thereafter as may be practicable.

[signature page follows]


If you have any questions with respect to this matter, please contact David C. Buck of Sidley Austin LLP at (713) 495-4521.

Very truly yours,

INDEPENDENCE CONTRACT DRILLING, INC.


By: ​ ​/s/ Philip A. Choyce​ ​​ ​

Name: Philip A. Choyce

Title: Executive Vice President, Chief Financial Officer, Treasurer and Secretary

Acceleration Request Letter