STAR BULK CARRIERS CORP.
40 Agiou Konstantinou Street
Maroussi, 15124
Athens, Greece
September 23, 2014
VIA EDGAR
Securities and Exchange Commission
Judiciary Plaza
100 F Street, N.E.
Washington, D.C. 20549
Star Bulk Carriers Corp.
and all other Registrants identified herein
Registration Statement on Form F-3 (File No. 333-197886)
Ladies and Gentlemen:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, Star Bulk Carriers Corp., a Marshall Islands corporation (the “Issuer”) and certain of the subsidiaries of the Issuer listed on the signature block hereto (the “Subsidiaries” and together with the Issuer, the “Registrants”), hereby request that the effective date of the above-captioned Registration Statement on Form F-3 (the “Registration Statement”) be accelerated to September 25, 2014 at 11:00 a.m. Eastern time or as soon thereafter as may be practicable.
We understand that the staff of the Securities and Exchange Commission (the “Commission”) will consider this request as confirmation by each of the Registrants of its awareness of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. In connection with the foregoing, each of the Registrants represents and acknowledges that:
| · | should the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| · | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| · | the Registrants may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
| Securities and Exchange Commission | 2 |
If you have any questions regarding the foregoing, please contact Robert E. Lustrin (212-480-8421) of Seward & Kissel LLP or Lawrence G. Wee (212-373-3052) of Paul, Weiss, Rifkind, Wharton & Garrison LLP.
Sincerely,
| Star Bulk Carriers Corp. | ||
| By: | /s/ Simos Spyrou | |
| Name: | Simos Spyrou | |
| Title: | Co-Chief Financial Officer | |
| Star Bulk Management Inc. | Cape Horizon Shipping LLC |
| Starbulk S.A. | Cape Ocean Maritime LLC |
| Star Alpha LLC | L.A. Cape Shipping LLC |
| Star Beta LLC | Grain Shipping LLC |
| Star Gamma LLC | Glory Supra Shipping LLC |
| Star Delta LLC | Global Cape Shipping LLC |
| Star Epsilon LLC | Sky Cape Shipping LLC |
| Star Zeta LLC | Pacific Cape Shipping LLC |
| Star Theta LLC | Cape Confidence Shipping LLC |
| Star Kappa LLC | Cape Runner Shipping LLC |
| Lamda LLC | Olympia Shiptrade LLC |
| Star Omicron LLC | Victory Shipping LLC |
| Star Cosmo LLC | Sea Cape Shipping LLC |
| Star Ypsilon LLC | Coral Cape Shipping LLC |
| Star Aurora LLC | Aurelia Shipping LLC |
| Star Borealis LLC | Pearl Shiptrade LLC |
| Star Polaris LLC | Rainbow Maritime LLC |
| Star Big LLC | Sea Diamond Shipping LLC |
| Star Mega LLC | Majestic Shipping LLC |
| Star Bulk Manning LLC | Nautical Shipping LLC |
| Star Challenger I LLC | Mineral Shipping LLC |
| Star Challenger II LLC | White Sand Shipping LLC |
| Star Vega LLC | Clearwater Shipping LLC |
| Star Sirius LLC | Domus Shipping LLC |
| Star Castle I LLC | Festive Shipping LLC |
| Star Castle II LLC | Gravity Shipping LLC |
| Star Ennea LLC | Orion Maritime LLC |
| Star Cape I LLC | Spring Shipping LLC |
| Star Cape II LLC | Success Maritime LLC |
| Star Asia I LLC | Ultra Shipping LLC |
| Star Asia II LLC | Searay Maritime LLC |
| Star Axe I LLC | Blooming Navigation LLC |
| Star Axe II LLC | Oday Marine LLC |
| Star Seeker LLC | Jasmine Shipping LLC |
| Star Breezer LLC | Star Synergy LLC |
| Oceanbulk Shipping LLC | Star Omas LLC |
| Oceanbulk Carriers LLC | Dioriga Shipping Co. |
| Premier Voyage LLC | Positive Shipping Company |
| Oocape I Holdings LLC | International Holdings LLC |
| KMSRX Holdings LLC | Star Bulk (USA) LLC |
| By: | /s/ Robert E. Lustrin | |
| Name: | Robert E. Lustrin | |
| Title: | Attorney-in fact |
| cc: | Lawrence G. Wee, Esq., Paul, Weiss, Rifkind, Wharton & Garrison LLP |
| Robert E. Lustrin, Esq., Seward & Kissel LLP |