February 8, 2018
VIA EDGAR
United States Securities and Exchange Commission
The Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-3561
| Re: | Gulfport Energy Corporation (the “Registrant”) and subsidiary guarantors listed on Schedule I hereto (“Co-Registrants” and, together with the Registrant, the “Registrants”) |
Registration Statement on Form S-4
File No. 333-222592
Ladies and Gentlemen:
Reference is made to the Registration Statement on Form S-4 (File No. 333-222592), filed by the Registrants with the Securities and Exchange Commission (the “Commission”) on January 18, 2018 (the “Registration Statement”). Pursuant to Rule 461 of the Securities Act of 1933, as amended, the Registrants respectfully request that the effective date for the Registration Statement be accelerated to February 12, 2018 at 4:00 p.m. Washington, D.C. time or as soon thereafter as practicable.
The Registrants acknowledge that:
| • | should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Registrants 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. |
If you have any questions with respect to the foregoing, please do not hesitate to call me at (405) 252-4517 or Seth R. Molay, P.C. of Akin Gump Strauss Hauer & Feld LLP at (214) 969-4780.
| Sincerely, |
| GULFPORT ENERGY CORPORATION |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
3001 Quail Springs Parkway, Oklahoma City, Oklahoma 73134, (405) 252-4600 www.gulfportenergy.com
United States Securities and Exchange Commission
February 8, 2018
Page 2
| JAGUAR RESOURCES LLC |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
| PUMA RESOURCES, INC. |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
| GATOR MARINE, INC. |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
| GATOR MARINE IVANHOE, INC. |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
| WESTHAWK MINERALS LLC |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
| GULFPORT APPALACHIA, LLC |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
| GULFPORT MIDSTREAM HOLDINGS, LLC |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
| GULFPORT MIDCON, LLC |
| /s/ Keri Crowell |
| Keri Crowell |
| Chief Financial Officer |
| cc: | Seth R. Molay, P.C. |
Akin Gump Strauss Hauer & Feld LLP
United States Securities and Exchange Commission
February 8, 2018
Page 3
SCHEDULE I
CO-REGISTRANTS
| 1. | Jaguar Resources LLC, a Delaware limited liability company |
| 2. | Puma Resources, Inc., a Delaware corporation |
| 3. | Gator Marine, Inc., a Delaware corporation |
| 4. | Gator Marine Ivanhoe, Inc., a Delaware corporation |
| 5. | Westhawk Minerals LLC, a Delaware limited liability company |
| 6. | Gulfport Appalachia, LLC (formerly known as Gulfport Buckeye LLC), a Delaware limited liability company |
| 7. | Gulfport Midstream Holdings, LLC, a Delaware limited liability company |
| 8. | Gulfport MidCon, LLC, a Delaware limited liability company |