ION GEOPHYSICAL CORPORATION
2105 CityWest Blvd., Suite 100
Houston, Texas 77042
December 20, 2019
Via EDGAR
U.S. Securities and Exchange Commission
100 F Street, NE, Mail Stop 3561
Washington, D.C. 20549
Attention: Karina Dorin
Re: | ION GEOPHYSICAL CORPORATION |
| Registration Statement on Form S-3 |
| File No. 333-234606 |
Dear Ms. Dorin:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, ION GEOPHYSICAL CORPORATION (the “Registrant”) hereby requests acceleration of effectiveness of its Registration Statement on Form S-3, as amended (File No. 333-234606), to December 23, 2019 at 4:30 p.m. Eastern Time, or as soon as possible thereafter.
| ION GEOPHYSICAL CORPORATION |
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| Very truly yours, |
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| /s/ Matthew Powers |
| Matthew Powers |
| Executive Vice President, General Counsel, and Corporate Secretary |
cc: | Locke Lord LLP |
| Eric Johnson |