 | 600 Third Avenue 39th Floor New York, NY 10016 USA | Tel: +1 212-251-1199 Fax: +1 212-251-1180
E-mail: jsmall@intlseas.com | James D. Small III Chief Administrative Officer, Senior Vice President, |
August 29, 2018
VIA EDGAR CORRESPONDENCE
Ms. Sonia Bednarowski
Division of Corporate Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | International Seaways, Inc. | |
| Registration Statement on Form S-3 (File No. 333-226946) |
Dear Ms. Bednarowski:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, International Seaways, Inc. (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form S-3, as amended, be accelerated so that it will be declared effective by 4:00 pm, Eastern Time, on Thursday, August 30, 2018, or as soon thereafter as reasonably practicable (the “Effective Date”).
The Company hereby acknowledges its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the above-referenced Registration Statement. In addition, the Company hereby acknowledges that:
| · | should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
| · | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and |
| · | the Company 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. |
Ms. Laura Nicholson
August 29, 2018
Page 2
Please contact Jeffrey D. Karpf of Cleary Gottlieb Steen & Hamilton LLP at (212) 225-2864, counsel to the Company, if you have any questions or concerns regarding this matter.
| Very truly yours, | |||
| International Seaways, Inc. | |||
| By: | /s/ James D. Small III | ||
| Name: | James D. Small III | ||
| Title: | Chief Administrative Officer, Senior Vice President, Secretary and General Counsel | ||
| cc: | Lois K. Zabrocky |
| International Seaways, Inc. | |
| Jeffrey D. Karpf, Esq. | |
| Marc Rotter, Esq. | |
| Cleary Gottlieb Steen & Hamilton LLP |