(212) 574-1223
July 21, 2005
By Hand and Via Edgar
Jennifer G. Williams, Esq.
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0305
| Re: | Genco Shipping and Trading Limited |
|
| Amendment No. 6 to Registration Statement on Form S-1 |
|
| File No. 333-124718 |
Dear Ms. Williams:
Genco Shipping & Trading Limited (the “Company”), has filed today via EDGAR Amendment No. 6 to its Registration Statement on Form S-1 (“Amendment No. 6”) under the Securities Act of 1933, as amended, in connection with its proposed initial public offering of common stock (the “Offering”).
Amendment No. 6 is filed for the sole purpose of adding Exhibit 3.3, Amendment to the Company’s Articles of Incorporation, and Exhibit 5, the revised validity opinion of Seward & Kissel LLP, reflecting a comment received from the Staff earlier today.
The Company and the underwriters have scheduled pricing to take place after 4:00 pm this afternoon. Accordingly, we would greatly appreciate any comments that the Staff may have as soon as possible today.
Please feel free to contact the undersigned at (212) 574-1223, Renee Eubanks at (212)
574-1349, or Sean Caley at (212) 574-1257, with any questions or comments.
|
| Very truly yours, |
|
|
|
|
| SEWARD & KISSEL LLP |
|
|
|
|
|
|
|
|
|
| by: | /s/ Gary J. Wolfe |
|
| Gary J. Wolfe |
|
|
|
|
|
|
Enclosures
cc: Rolaine S. Bancroft, Esq.
2