United States securities and exchange commission logo February 10, 2021 Michael D. Prinn Chief Financial Officer SEACHANGE INTERNATIONAL INC 500 Totten Pond Road Waltham, MA 02451 Re: SEACHANGE INTERNATIONAL INC Registration Statement on Form S-3 Filed February 5, 2021 File No. 333-252777 Dear Mr. Prinn: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Beverly Singleton at (202) 551-3328 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing