November 28, 2022
VIA EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Top Ships Inc.
Registration Statement on Form F-1, as amended
Originally filed on September 22, 2022
File No. 333-267545
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Maxim Group LLC, as placement agent, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 9:00 a.m., Washington D.C. time, on Wednesday, November 30, 2022, or as soon thereafter as may be practicable.
Pursuant to Rule 460 of the General Rules and Regulations under the Act, the undersigned advises that copies of the Preliminary Prospectus dated October 20, 2022 have been distributed to prospective dealers, institutional investors, retail investors and others.
The undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
| Very truly yours, | ||
| Maxim Group LLC | ||
| By: | /s/ Clifford A. Teller | |
| Name: Clifford A. Teller Title: Co-President | ||
