December 11, 2013
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
Attention: John Dana Brown
| Re: | Scorpio Bulkers Inc. (“Company”) |
| Amended Registration Statement on Form F-1 and |
| Amended Registration Statement on Form F-4 |
| Filed December 11, 2013 |
| CIK No. 0001587264 |
Dear Mr. Brown,
Reference is made to Amendment No. 3 to the Company’s Registration Statement on Form F-1 (the “F-1 Registration Statement”), filed with the Securities and Exchange Commission (the “Commission”) on December 6, 2013 and Amendment No. 1 to the Company’s Registration Statement on Form F-4 (the “F-4 Registration Statement”), filed with the Commission on November 27, 2013. The Company has today filed via EDGAR (i) Amendment No. 4 to its Registration Statement on Form F-1 (the “Amended F-1 Registration Statement”) (File No. 333-192246), and a letter related thereto, which responded to the Staff’s comments contained in the letter dated December 9, 2013; and (ii) Amendment No. 3 to its Registration Statement on Form F-4 (“Amended F-4 Registration Statement) (File No. 333-192247), and a letter related thereto, which responded to the Staff’s comments contained in the letter dated December 5, 2013.
In this connection, enclosed herewith are the following documents:
(1) Amended F-1 Registration Statement, marked to show changes from the F-1 Registration Statement, attached hereto as Exhibit A; and
(2) Amended F-4 Registration Statement, marked to show changes from the F-4 Registration Statement, attached hereto as Exhibit B.
If you have any questions or comments concerning the enclosed, please feel free to telephone the undersigned at (212) 574-1265, Keith Billotti at (212) 574-1274 or Filana Silberberg at (212) 574-1308.
| Very truly yours, | ||
| SEWARD & KISSEL LLP | ||
| By: | /s/ Edward S. Horton | |
| Edward S. Horton | ||