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                             May 21, 2021

       Melisss Cougle
       Chief Financial Officer
       Frank's International N.V.
       Mastenmakersweg
       1786 PB Den Helder
       The Netherlands

                                                        Re: Frank's
International N.V.
                                                            Registration
Statement on Form S-4
                                                            Filed April 26,
2021
                                                            File No. 333-255496

       Dear Ms. Cougle:

              We have reviewed your registration statement and have the
following comments. In
       some of our comments, we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-4

       Questions and Answers
       Q: What are the material U.S. federal income tax consequences to the
Franks shareholders as a
       result of the Merger?, page 11

   1.                                                   We note your disclosure
that there should be no material U.S. federal income tax
                                                        consequences to the
current Frank   s shareholders as a result of the Merger. We also note
                                                        that in rendering its
fairness opinion, Moelis assumed, with your consent, that the
                                                        transaction will
qualify as a tax free reorganization for federal income purposes and that
                                                        one of the factors that
the Frank   s Board considered in approving and recommending
                                                        approval of the merger
was that it was intended to qualify for federal income tax purposes
                                                        as a reorganization
within the meaning of Section 368(a) of the Code. In this regard, we
 Melisss Cougle
FirstName  LastNameMelisss
Frank's International N.V. Cougle
Comapany
May         NameFrank's International N.V.
     21, 2021
May 21,
Page 2 2021 Page 2
FirstName LastName
         note that Section 5.14(a) merger agreement provides that the parties
intend that the merger
         qualifies as a    reorganization    within the meaning of Section
368(a) of the Code. Please
         revise to state clearly whether the transaction will qualify as a
reorganization and file an
         opinion as to the material tax consequences of the merger. Refer to
Item 601(b)(8) of
         Regulation S-K and Section III of Staff Legal Bulletin No. 19.
Summary
Treatment of Expro Warrants, page 20

2.       We note your disclosure that immediately prior to the effective time
Frank's will execute a
         replacement warrant agreement and issue a replacement warrant. Please
file a form of
         replacement warrant agreement as an exhibit to your registration
statement or tell us why
         you believe you are not required to do so.
Risk Factors, page 32

3.       Please ensure that you have provided all information required by Item
105 of Regulation
         S-K with respect to Expro.
Opinion of Frank's Financial Advisor
Discounted Cash Flow Analysis - Standalone, page 71

4.       We note that Moelis selected the terminal value multiple range for
Frank's and Expro by
         reference to the long-term trading multiples of the selected companies
described in the
         filing for the calendar years 2008 through 2014. Please expand your
disclosure to discuss
         the rationale for choosing the calendar years 2008 through 2014 for
the long-term trading
         multiples.
Selected Publicly Traded Companies Analysis - Standalone, page 73

5.       Please discuss whether any companies meeting the selection criteria
were excluded from
         the Offshore Focused Products and Manufacturing selected companies in
Moelis's
         Selected Publicly Traded Companies Analysis. In addition, please
clarify the impact on
         the analysis, if any, of Moelis's determination that manufacturing
companies included in
         the selected companies were less relevant due to such companies having
significantly
         more onshore and manufacturing focused operations when compared to
Frank's and
         Expro.
Discounted Cash Flow Analysis - Pro Forma Combined, page 76

6.       Please clarify the equity risk premium and size premium utilized in
determining the
         WACC range.
Miscellaneous, page 78

7.       Please revise your disclosure to quantify the opinion fee and
transaction fee paid or to be
         paid to Moelis for delivery of its fairness opinion and the specific
amount of the fee that is
 Melisss Cougle
Frank's International N.V.
May 21, 2021
Page 3
         contingent upon the consummation of the transaction. In that regard,
we note that the
         fairness opinion states on page B-3 that in addition to its opinion
fee, Moelis will receive a
         fee for acting as financial advisor in connection with the
transaction, the principal portion
         of which is contingent upon the consummation of the transaction. Refer
to Item 1015(b)
         of Regulation M-A.
Unaudited Prospective Financial Information, page 79

8.       Please describe and quantify, as applicable, the material market
growth assumptions, such
         as oil and gas commodity prices, domestic and international rig and
well counts, and
         global drilling and completion spending that underlie the projected
financial information.
Material Dutch Tax Consequences, page 148

9.       We note your discussion of Dutch tax consequences in this section.
Item 601(b)(8) of
         Regulation S-K requires you to file a tax opinion where the tax
consequences are material
         to an investor and a representation as to the tax consequences is set
forth in the
         filing. Please file a tax opinion as an exhibit to the filing with
respect to such tax
         consequence, or provide your analysis as to why you do not believe
such an opinion is
         required. For guidance, please refer to Section III of Staff Legal
Bulletin No. 19.
Unaudited Pro Forma Condensed Combined Financial Information
Notes to Pro Forma Condensed Combined Financial Statements
4. Estimated Preliminary Merger Consideration and the Preliminary Purchase
Price Allocation,
page 159

10.      Based on disclosure in footnote 6(a) on page 163, we note the
identifiable tangible and
         intangible assets acquired and liabilities assumed of Frank's include
trademarks,
         tradename, customer relationships, patented technology and research
and development
         intangible assets, and each of the intangible assets have an estimated
useful life of 10
         years. Please expand your disclosure to describe the methods and key
assumptions used
         to estimate the fair values of the identified intangible assets and
explain how the estimated
         useful lives were determined.
5. Notes to Unaudited Pro Forma Condensed Combined Balance Sheet Pro Forma
Adjustments,
page 161

11.    Please tell us why there are no transaction accounting adjustments for
deferred taxes given
FirstName LastNameMelisss Cougle
       the recognition of goodwill and intangible assets upon your preliminary
allocation of the
Comapany    NameFrank's
       estimated          International
                  preliminary             N.V.
                               merger consideration  to the identifiable
tangible and intangible
       assets acquired
May 21, 2021 Page 3    and  liabilities assumed of Frank's.
FirstName LastName
 Melisss Cougle
FirstName  LastNameMelisss
Frank's International N.V. Cougle
Comapany
May         NameFrank's International N.V.
     21, 2021
May 21,
Page 4 2021 Page 4
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
Expro
Results of Operations
Year ended December 31, 2020 Compared to year ended December 31, 2019, page 189

12.      We note that you provide multiple factors for the increase or decrease
of revenue, cost of
         revenue, general and administrative expenses and other line items of
your consolidated
         statements of operations. Please expand your disclosures to quantify
the significant
         factors that contributed to the period to period changes. To the
extent applicable, similar
         revisions should also be included in your discussion of operating
segment results. Refer
         Item 303(b) of Regulation S-K.
Year ended December 31, 2019 compared to the 2018 Periods, page 191

13.      We note your presentation of the combined results for the predecessor
and successor
         periods for the year ended December 31, 2018 when discussing the
results of operations
         and cash flows from operating, investing and financing activities in
Management's
         Discussion and Analysis. Please note that it is generally
inappropriate to combine the
         financial information for predecessor and successor periods for
purposes of MD&A as the
         financial statements are prepared on a different bases of accounting
and are therefore not
         comparable. In this regard, please revise your MD&A to separately
present and discuss
         the historical results of your predecessor and successor or explain to
us how your
         presentation complies with Item 303 of Regulation S-K. To the extent
you include
         supplemental comparative discussion of the results for fiscal years
2019 and 2018
         prepared on a pro forma basis, it should reflect all relevant pro
forma adjustments in
         accordance with Article 11 of Regulation S-X.
Net Cash Provided by Operating Activities, page 198, page 198

14.      Please revise your disclosure to quantify and discuss the underlying
reasons for the
         material changes in your operating cash flows, as depicted in the
consolidated statement
         of cash flows. Refer to Section IV.B.1 of SEC Release No. 33-8350.
Directors of the Combined Company, page 205

15.      Please provide the disclosure required by Item 402 of Regulation S-K
for Messrs. Jardon,
         Fanning, Truelove, Arbeter and Schrager. Refer to Item 18(a)(7) of
Form S-4.
Security Ownership of Certain Beneficial Owners and Management, page 222

16.      Please revise to provide the information required by Item 403 of
Regulation S-K with
         respect to Expro and the combined company. Refer to Item 18(a)(5)(ii)
of Form S-4.
 Melisss Cougle
FirstName  LastNameMelisss
Frank's International N.V. Cougle
Comapany
May         NameFrank's International N.V.
     21, 2021
May 21,
Page 5 2021 Page 5
FirstName LastName
Notes to the Consolidated Financial Statements
5. Segment Information, page F-62, page F-62

17.      We note on page F-20 that during 2020 you changed your internal
organization and
         reporting structure to combine your Europe and the Commonwealth of
Independent States
         (   ECIS   ) and Sub-Saharan Africa (   SSA) operating segments into
one segment Europe
         and Sub-Sahara Africa (ESSA   ). Please tell us why you did not
restate previously
         reported reportable segment information pursuant to ASC 280-10-50-34.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Steve Lo, Staff Accountant, at (202) 551-3394 or Myra
Moosariparambil, Staff Accountant, at (202) 551-3796 if you have questions
regarding
comments on the financial statements and related matters. Please contact Karina
Dorin, Staff
Attorney, at (202) 551-3763 or Laura Nicholson, Special Counsel, at (202)
551-3584 with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Energy &
Transportation
cc:      Michael S. Telle