December 7, 2005

Via U.S. Mail and Facsimile

Robert Brunck
Chief Executive Officer
Compagnie Generale de Geophysique
1 Rue Leon Migaux
91300 Massy
France

RE:		Compagnie Generale de Geophysique
		Form 20-F, Amendment No. 2,
		for the fiscal year ended December 31, 2004
		File No. 001-14622

Dear Mr. Brunck:

      We have limited our review of your Form 20-F for the fiscal
year ended December 31, 2004, to disclosures relating to your
contacts with countries that have been identified as state
sponsors
of terrorism, and will make no further review of the Form 20-F.
Our
review with respect to this issue does not preclude further review
by
the Assistant Director group with respect to other issues.  At
this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may or may not raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


General -

We note that you state on page 20 of your 20-F/A that you have
"developed partnerships with local seismic acquisition companies
in
several countries" including Libya.  A March 2003 article reports
that you were hired to conduct a seismic survey of a Cuban oil
block.
Information identified as your contact information in Syria is
available on the internet.  Additionally, a May 2005 news article
reports that you were awarded a contract to carry out a seismic
survey of Iran`s South Pars gas field.

In light of the fact that Cuba, Iran, Syria and Libya have been
identified by the U.S. State Department as state sponsors of
terrorism; Cuba, Iran and Syria are subject to economic sanctions
administered by the U.S. Treasury Department`s Office of Foreign
Assets Control; and Libya was subject to similar OFAC-administered
sanctions until September 21, 2004, please describe for us your
operations and/or contacts in each of these countries, including
the
amount of revenue derived from the operations and/or contacts; the
materiality to you of your operations and/or contacts in each
country; and your view as to whether those operations and/or
contacts, individually or in the aggregate, constitute a material
investment risk for your security holders.  In addressing
materiality
and investment risk, please provide both your conclusions and your
underlying analysis.

In preparing your response please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors that a reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.  In this regard, we note
that
Arizona and Louisiana have adopted legislation that requires their
state retirement systems to prepare reports regarding state
pension
fund assets invested in, and/or permits divestment of state
pension
fund assets from, companies that do business with U.S.-designated
state sponsors of terrorism.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.


      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk


cc: 	Roger Schwall
		Assistant Director
		Division of Corporation Finance

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Robert Brunck
Compagnie Generale de Geophysique
December 7, 2005
Page 3









UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0507

         DIVISION OF
CORPORATION FINANCE