UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE


							April 1, 2005

via facsimile and U.S. mail

Mr. Gregory L. Cauthen
Chief Financial Officer
Transocean Inc.
P.O. Box 2765
Houston, TX 77252


	Re:	Transocean Inc.
		Form 10-K, Filed March 16, 2005
		Response letter dated February 25, 2005
      File No. 333-75899

Dear Mr. Cauthen:

      We have reviewed the above filing and response letter and
have
the following comments.  Our review has been limited to the areas
commented on below.  Please be as detailed as necessary in the
explanations you provide for these comments.  After reviewing this
information, we may or may not raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

10-K for the year ended December 31, 2004

Business, page 3

	Transocean Drilling Fleet tables, pages 6-9

1. We have read your response to prior comment 1, where you
indicate
that "cash flows from a rig are dependent upon other rigs within
the
asset class" because "the availability of another competing rig
has a
direct influence on the dayrates bid for a job and consequently
the
cash flow derived from that contract."  You further explain that
the
"supply / demand dynamic is a reason why the asset class level is
the
lowest level that cash flows are independent of each other."
While
we recognize that the grouping of long-lived assets requires
significant judgment, as indicated by paragraph B45 of SFAS 144,
we
do not believe that offsetting is appropriate within the asset
class
level because an individual rig can be an individual source of
cash
flows.  Even though rigs within an asset class are
interchangeable,
that interchangeability can be influenced by your marketing
through
decisions to "cold-stack" certain rigs within a particular market
sector.  Since you are capable of generating discrete financial
information on an individual rig basis and individual rigs can be
largely independent of one another based on marketing efforts, it
appears that individual rigs are the lowest level for which
identifiable cash flows are largely independent of the cash flows
of
other assets and liabilities.

2. With respect to your response to part d) of prior comment 1,
please tell us the factors you considered in your determination
that
your operating segments have similar economic characteristics as
identified by paragraph 17 of SFAS 131.

Closing Comments

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your response to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

	the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.
      Direct questions to Jennifer Goeken at (202) 824-5287, or in
her absence, to Barry Stem, Senior Assistant Chief Accountant, at
(202) 942-1919.  Direct questions relating to all other disclosure
issues to the undersigned at (202) 942-1870.  Direct all
correspondence to the following ZIP code:  20549-0405.


							Sincerely,



							H. Roger Schwall
							Assistant Director
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Transocean Inc.
April 1, 2005
page 1