Response of the Office of International Corporate Finance
Division of Corporation Finance

March 3 , 2021

Re: Transocean Ltd.
       Incoming letter dated February 22, 2021

Based on the facts presented, the Division will not object if Transocean Ltd. were to file a definitive proxy statement without filing a preliminary proxy statement for the proposals, as described in your incoming letter, that are required to be submitted for shareholder approval at an annual meeting under the laws of Switzerland. Foreign issuers organized under the laws of Switzerland may rely on this letter with respect to the proposals described in your incoming letter.

This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion.