David L. Roland
Senior Vice President,
General Counsel and
Corporate Secretary

July 13, 2010

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549

Attention: Alexandra M. Ledbetter

Re:  ION Geophysical Corporation
Registration Statement on Form S-3
Filed April 20, 2010
File No. 333-166200

Ladies and Gentlemen:

          The undersigned, ION Geophysical Corporation (“ION”), hereby requests that the effectiveness of the above-referenced registration statement be accelerated to Thursday, July 15, 2010, at 9:00 a.m. (Eastern time), or as soon thereafter as practicable.

          In connection with this request for acceleration of the above-referenced registration statement, ION hereby confirms its awareness of its obligations under the Securities Act of 1933, as amended.

          Should you have any questions, please do not hesitate to contact Marc H. Folladori of Mayer Brown LLP at (713) 238-2696, or the undersigned at (281) 552-3308.

Very truly yours, ION GEOPHYSICAL CORPORATION
By:	/s/ David L. Roland
	David L. Roland
	Senior Vice President, General Counsel and Corporate Secretary

2105 CityWest Blvd., Suite 400
Houston, TX 77042-2839
[p] +1 281 552 3308 [f] +1 281 879 3600
www.iongeo.com