March 4, 2011
Via EDGAR
Mr. H. Roger Schwall
Assistant Director
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7010
Re: |
Geokinetics Inc. |
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Form 10-K/A for the Fiscal Year Ended December 31, 2009 |
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Filed August 9, 2010 |
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Definitive Proxy Statement filed March 29, 2010 |
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Response Letter Dated October 20, 2010 |
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File No. 001-33460 |
Dear Mr. Schwall:
Geokinetics Inc. (the Company) hereby submits the following responses to your letter dated March 3, 2011, containing comments from the staff of the Securities and Exchange Commission (the Staff) relating to the Companys Form 10-K/A, Definitive Proxy Statement and Response Letter dated October 20, 2010.
In this letter, we have reproduced your comments in italics typeface, and have made our responses in normal typeface. In addition, the numbered paragraphs of this letter correspond to the numbered paragraphs of the Comment Letter. We respectfully request that the Staff provide its further comments at its earliest convenience.
Definitive Proxy Statement filed March 29, 2010
Director Compensation, page 36
1. We note your response to comment 6 in our letter dated September 24, 2010. Please confirm that you will also disclose in your 2011 proxy statement the aggregate number of stock option awards outstanding at fiscal year end, or explain why you believe this is not required. In this regard, we note that your proposed disclosure submitted in response to our comment was limited to restricted stock awards.
Response: In response to the Staffs comment, the Company hereby confirms that it will disclose in its 2011 proxy statement the aggregate number of stock option awards outstanding at fiscal year end.
If this letter does not adequately answer all of your questions, or if you have any further questions, please contact the undersigned and we will supply further detail as quickly as possible.
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Sincerely, |
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/s/ William L. Moll, Jr. |
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William L. Moll, Jr. |
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Vice President, General Counsel & Secretary |
cc: |
George G. Young III, Esq. |
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Haynes and Boone, LLP |