March 20, 2019

Bernie G. Wolford Jr.
Chief Executive Officer
Pacific Drilling S.A.
8-10 Avenue de la Gare
L-1610 Luxembourg

       Re: Pacific Drilling S.A.
           Registration Statement on Form F-3
           Filed March 12, 2019
           File No. 333-230231

Dear Mr. Wolford Jr.:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

       Please contact Karina Dorin, Staff Attorney, at (202) 551-3763 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Natural
Resources