United States securities and exchange commission logo





                              May 7, 2021

       Robert W. Eifler
       President and Chief Executive Officer
       Noble Corporation
       13135 Dairy Ashford, Suite 800
       Sugar Land, Texas 77478

                                                        Re: Noble Corporation
                                                            Registration
Statement on Form S-1
                                                            Filed April 21,
2021
                                                            File No. 333-255406

       Dear Mr. Eifler:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comments. In some of our comments, we may ask you to
provide us with
       information so we may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-1

       General

   1.                                                   We note your disclosure
that selling shareholders will determine at what price they may
                                                        sell the ordinary
shares offered by this prospectus, and such sales may be made at fixed
                                                        prices, at prevailing
market prices at the time of the sale, at prices related to prevailing
                                                        market prices or at
negotiated prices. We further note your disclosure that there is
                                                        currently no public
trading market for your ordinary shares, but that you intend to apply
                                                        for a listing of the
ordinary shares on a national securities exchange. Accordingly, please
                                                        revise your prospectus
cover page, and elsewhere as appropriate, to disclose an initial
                                                        fixed price or bona
fide price range at which the shares of your common stock will be sold
                                                        until such shares are
listed on a national securities exchange or quoted on a trading market
                                                        such as the OTC
Bulletin Board, OTCQX or OTCQB, at which time they may be sold at
 Robert W. Eifler
Noble Corporation
May 7, 2021
Page 2
      prevailing market prices or in privately negotiated transactions or
update with the listing
      approval. Refer to Item 501(b)(3) of Regulation S-K.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Irene Barberena-Meissner, Staff Attorney, at
202-551-6548 or Loan
Lauren Nguyen, Legal Branch Chief, at 202-551-3642 with any other questions.



                                                            Sincerely,
FirstName LastNameRobert W. Eifler
                                                            Division of
Corporation Finance
Comapany NameNoble Corporation
                                                            Office of Energy &
Transportation
May 7, 2021 Page 2
cc:       Clinton W. Rancher, Esq.
FirstName LastName