CORRESP 5 filename5.htm d1299782a_corresp.htm
 
SEWARD & KISSEL LLP
ONE BATTERY PARK PLAZA
NEW YORK, NEW YORK  10004
  
     
WRITER'S DIRECT DIAL
(212) 574-1420
TELEPHONE:  (212)  574-1200
FACSIMILE:  (212) 480-8421
WWW.SEWKIS.COM
901 K STREET, NW
WASHINGTON, D.C. 20001
TELEPHONE:  (202) 737-8833
FACSIMILE:  (202) 737-5184
       
 
 
 
 
     July 2, 2012
 
 
 
                                  
VIA EDGAR
Ms. Julie Rizzo
Attorney-Advisor
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
 
    Re:
Star Bulk Carriers Corp.
Amendment No. 1 to
Registration Statement on Form F-3
Filed May 31, 2012
File No. 333-180674

 
Dear Ms. Rizzo:
 
We refer to Amendment No. 1 to registration statement on Form F-3 under File No. 333-180674 (the "Amended Registration Statement") filed by Star Bulk Carriers Corp. (the "Company") with the Securities and Exchange Commission (the "Commission") on May 31, 2012.  By letter dated June 13, 2012 (the "Comment Letter") the staff of the Commission (the "Staff") provided the Company with its comments regarding the Amended Registration Statement.
 
The Company has today filed via EDGAR Amendment No. 2 to the Registration Statement (the "Second Amended Registration Statement"), which responds to the Staff's comments contained in the Comment Letter.  The Second Amended Registration Statement also includes certain updates related to the passage of time.
 
This letter responds to the Staff's Comment Letter.  The following numbered paragraphs correspond to the numbered paragraphs in the Comment Letter.
 
Signatures, page 43
 
 
1.
Please revise the second half of the signature block for Star Bulk Carriers Corp. to indicate the capacity in which each person is signing and to have at least a majority of the board of directors sign the registration statement.
 
In response to the Staff's comment, the Company has revised the signature block for Star Bulk Carriers Corp. to indicate the capacity in which each person is signing and the entire board of directors has signed the registration statement.

 
 
 
Ms. Julie Rizzo
Attorney-Advisor
Division of Corporation Finance
U.S. Securities and Exchange Commission
July 2, 2012
Page 2


 
 
2.
We note your response to our prior comment 5 and reissue in part. Please revise the signature page for each co-registrant so that the registration statement is signed by at least a majority of the board of directors or persons performing similar functions for each co-registrant. Refer to the instructions for signatures on Form F-3.
 
In response to the Staff's comment, the Company has revised the signature page for each co-registrant so that at least a majority of the board of directors or persons performing similar functions for each co-registrant has signed.
 
*******************
The Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the filing; Staff comments or changes to the disclosure in response Staff comments do not foreclose the Commission from taking any action with respect to the filing; and the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
 
*******************
 
If you have any questions or comments concerning this letter, please feel free to contact the undersigned at (212) 574-1420, Christine Westbrook, Esq. at (212) 574-1371 or Keith Billotti, Esq. at (212) 574-1274.
 
 
 
Very truly yours,
SEWARD & KISSEL, LLP
By: /s/ Robert E. Lustrin_
      Robert E. Lustrin, Esq.
 

 
John Dana Brown
Division of Corporate Finance
Securities and Exchange Commission

Spyros Capralos
Chief Executive Officer
Star Bulk Carriers Corp.