SEACOR Marine Holdings Inc.
12121 Wickchester Lane, Suite 500
Houston, TX 77079
April 29, 2019
Susan Block, Attorney-Advisor
J. Nolan McWilliams, Attorney-Advisor
Division of Corporation Finance
Office of Transportation and Leisure
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
RE: SEACOR Marine Holdings Inc., Registration Statement on Form S-3 Filed April 1, 2019, File No. 333-230667
Dear Ms. Block and Mr. McWilliams:
On behalf of SEACOR Marine Holdings Inc. (the Company), a Delaware corporation, we respond as follows to the Staffs comment letter, dated April 22, 2019, relating to the above-captioned Registration Statement on Form S-3 (Registration Statement).
Please note that for the Staffs convenience, we have recited the Staffs comment and provided the Companys response immediately thereafter.
Form S-3 filed April 1, 2019
Documents Incorporated by Reference, page 13
1. We note that your registration statement incorporates by reference your Form 10-K for the fiscal year ended December 31, 2018, which in turn incorporates by reference Part III from a proxy statement that you have not yet filed. Please be advised that we cannot accelerate the effective date of your registration statement until you have amended your Form 10-K to include Part III information or filed the definitive proxy statement. For guidance, please refer to Compliance and Disclosure Interpretations, Securities Act Forms Questions 123.01.
We acknowledge the Staffs comment and hereby inform the Staff that the Companys Definitive Proxy Statement on Schedule 14A was filed with the SEC on April 24, 2019.
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We thank the Staff for its attention to the Companys submission. If I can be of any assistance during the Staffs review of the enclosed draft Registration Statement, please contact me, collect, by telephone at (212) 530-5301 or by facsimile at (212) 822-5301. I can also be reached by e-mail at firstname.lastname@example.org.
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|Very truly yours,|
|/s/ Brett Nadritch, Esq.|
Mr. John Gellert, President and Chief Executive Officer of SEACOR Marine Holdings Inc.
Mr. Jesús Llorca, Executive Vice President and Chief Financial Officer of SEACOR Marine Holdings Inc.
Mr. Andrew H. Everett II, Senior Vice President, General Counsel and Secretary of SEACOR Marine Holdings Inc.
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