United States securities and exchange commission logo

                              December 8, 2021

       Jes  s Llorca
       Chief Financial Officer
       SEACOR Marine Holdings Inc.
       12121 Wickchester Lane
       Suite 500
       Houston, TX 77079

                                                        Re: SEACOR Marine
Holdings Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed March 12,
                                                            File No. 001-37966

       Dear Mr. Llorca:

             We have reviewed your filing and have the following comment. In
our comment, we
       may ask you to provide us with information so we may better understand
your disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to the comment, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Certain Components of Revenues and Expenses
       Direct Vessel Profit, page 43

   1.                                                   We note you have
identified the measure Direct Vessel Profit (DVP) as a non-GAAP
                                                        measure when applied to
individual vessels, fleet categories or the combined fleet. You
                                                        disclose that DVP is
defined as operating revenues less direct operating expenses
                                                        excluding leased-in
equipment expense. We also note your disclosure that DVP has some
                                                        limitations in that it
does not take into account all expense related to the operation of the
                                                        fleet and, more
significantly, the Company. Please address the following related to this

                                                              Clarify if the
operating revenues used in your calculation of DVP include leased-in
                                                            equipment revenue.
To the extent operating revenues include revenue from leased-in
 Jes  s Llorca
SEACOR Marine Holdings Inc.
December 8, 2021
Page 2
              equipment, please explain why you believe it is appropriate to
exclude the related
              costs and expenses in your non-GAAP presentation.

                Tell us how you considered reconciling DVP to the most directly
comparable GAAP
              measure, fully loaded GAAP gross margin. Refer to Item
10(e)(1)(i)(B) of Regulation

        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.

        You may contact Myra Moosariparambil at 202-551-3796 or Craig Arakawa
at 202-551-
3650 if you have questions regarding the comment.

FirstName LastNameJes  s Llorca                                 Sincerely,
Comapany NameSEACOR Marine Holdings Inc.
                                                               Division of
Corporation Finance
December 8, 2021 Page 2                                        Office of Energy
& Transportation
FirstName LastName