CORRESP 1 filename1.htm corresp
Endeavour International Corporation
1001 Fannin Street, Suite 1600
Houston, Texas 77002
February 5, 2010
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-3561
Attention: Mr. John Lucas
     
Re:
  Endeavour International Corporation (the “Registrant”)
 
  Request for Acceleration of Effectiveness
 
  Registration Statement on Form S-3 (File No. 333-163781), as amended, (the “Registration Statement”)
Ladies and Gentlemen:
     Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of 1933, the Registrant hereby requests that the effectiveness of the above-captioned Registration Statement be accelerated so that the Registration Statement will become effective Tuesday, February 9, 2010, at 1:00 p.m. Eastern Time, or as soon thereafter as practicable.
     The Registrant hereby acknowledges that the disclosure in the Registration Statement is the responsibility of the Registrant. The Registrant hereby further acknowledges that:
    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
 
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
 
    the Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 


 

     Please call Griff Aldrich of Vinson & Elkins L.L.P., the Registrant’s outside legal counsel, at 44.77.8963.7427 with any questions regarding this request for acceleration.
         
  Sincerely,

ENDEAVOUR INTERNATIONAL CORPORATION
 
 
  By:   /s/ J. Michael Kirksey    
    Name:   J. Michael Kirksey   
    Title:   Executive Vice President and Chief
Financial Officer 
 
 
         
     
cc:   Griff Aldrich, Esq.    
    Vinson & Elkins L.L.P.   
    Via Facsimile   
 

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