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ION Geophysical Corporation

2105 CityWest Blvd., Suite 100

Houston, Texas 77042

 

March 9, 2021

 

VIA EDGAR

 

Tim Levenberg

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 

  Re: ION Geophysical Corporation
    Registration Statement on Form S-1
    Filed March 3, 2021
    File No. 333-252590

 

Dear Mr. Levenberg:

 

Pursuant to Rule 461 under the Securities Act of 1933, as amended, ION Geophysical Corporation (the “Registrant”) hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. EDT on Wednesday, March 10, 2021 or as soon as thereafter practicable.

 

  Very truly yours,
   
  /s/ Michael Morrison
 

Michael Morrison

Executive Vice President and Chief Financial Officer

 

cc:

J. Eric Johnson

Partner, Winston & Strawn LLP

800 Capitol Street, Suite 2400

Houston, Texas 77002