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United States securities and exchange commission logo





                              July 9, 2021

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

                                                        Re: Frank's
International N.V.
                                                            Amendment No. 2 to
Registration Statement on Form S-4
                                                            Filed June 22, 2021
                                                            File No. 333-255496

       Dear Ms. Cougle:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our June
16, 2021 letter.

       Amendment No. 2 to Registration Statement on Form S-4

       Exhibit 5.1, page 2

   1.                                                   Please have counsel
revise its legal opinion to quantify the securities being registered
                                                        under the registration
statement, opine as to the due authorization of the replacement
                                                        warrants, and remove
the assumptions in clauses d., e. and g. of the legal opinion. It is not
                                                        appropriate for counsel
to include in its opinion assumptions that assume any of the
                                                        material facts
underlying the opinion. Refer to Section II.B.3.a of Staff Legal Bulletin No.
                                                        19.
 Melissa Cougle
FirstName   LastNameMelissa
Frank's International N.V. Cougle
Comapany
July 9, 2021NameFrank's International N.V.
July 9,2 2021 Page 2
Page
FirstName LastName
Material U.S. Federal Income Tax Consequences to the Frank's Shareholders as a
Result of the
Merger, page 96

2.       We note your response to prior comment 1. Please revise to state
clearly whether the
         transaction will qualify as a reorganization within the meaning of
Section 368(a) of the
         Code, and include a tax opinion from counsel supporting this
conclusion as appropriate.
         See Item 4(a)(6) of Form S-4, and Item 601(b)(8) of Regulation S-K.
For guidance, refer
         to Section III of Staff Legal Bulletin No. 19. In that regard, we note
that the registration
         statement constitutes a prospectus of Frank   s under the Securities
Act with respect to the
         shares of Frank   s common stock to be issued to Expro shareholders in
connection with the
         merger.
       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
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