TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo September 14, 2023 John Wobensmith Chief Executive Officer Genco Shipping & Trading Limited 299 Park Avenue, 12th Floor New York, New York 1017 Re: Genco Shipping & Trading Limited Definitive Proxy Statement on Schedule 14A Filed April 6, 2023 File No. 001-33393 Dear John Wobensmith: We have limited our review of your most recent definitive proxy statement to those issues we have addressed in our comments. Please respond to these comments by confirming that you will revise your future proxy disclosures in accordance with the topics discussed below. Definitive Proxy Statement on Schedule 14A filed April 6, 2023 Pay versus Performance, page 28 1. Please ensure that you identify each named executive officer included in the calculation of average non-PEO named executive officer compensation and the fiscal years in which such persons are included. You may provide this information in a footnote to the pay versus performance table. See Regulation S-K Item 402(v)(3). This information may not be provided by cross-reference to other sections of the proxy statement. 2. Please ensure that you revise your pay versus performance table to adjust the format of the heading "Value of Initial Fixed $ 100 Investment Based on:" to apply only to columns (f) and (g). 3. At the bottom of page 29 and top of page 30 you include identical graphs for disclosure that appears to be intended to reflect different relationships. Please ensure that the graphs reflect the intended information. John Wobensmith FirstName LastNameJohn Genco Shipping & TradingWobensmith Limited Comapany 14, September NameGenco 2023 Shipping & Trading Limited September Page 2 14, 2023 Page 2 FirstName LastName Please contact Alyssa Wall at 202-551-8106 or Charlie Guidry at 202-551-3621 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program