Goodwin Procter LLP 100 Northern Avenue Boston, MA 02210
goodwinlaw.com +1 617 570 1000 |
April 21, 2022
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Imperial Petroleum Inc. |
On behalf of our client, Imperial Petroleum Inc. (the “Company”), we have submitted a draft Registration Statement on Form F-1 (the “Draft Registration Statement”) relating to the proposed offering of the Company’s units, consisting of shares of its common stock and warrants to purchase shares of its common stock. The Draft Registration Statement was submitted via EDGAR to the Securities and Exchange Commission (the “Commission”) for review on a confidential basis in accordance with the procedures of the Commission. The Company confirms that the Draft Registration Statement is submitted prior to the end of the twelfth month following November 23, 2021, the effective date of the Registration Statement for the Company’s initial public offering of securities under the Securities Act of 1933, as amended, in connection with its spin-off from StealthGas Inc. The Company undertakes to publicly file its Registration Statement for this proposed offering no later than 48 hours prior to any requested effective date and time.
*****
Please contact the undersigned, Finn Murphy of Goodwin Procter LLP, at (212) 459-7257 if you have any questions with respect to the foregoing.
Very truly yours, | ||
GOODWIN PROCTER LLP | ||
By: | /s/ Finn Murphy | |
Finn Murphy |
cc: | Harry N. Vafias (Imperial Petroleum Inc.) |