Seward & Kissel llp
ONE BATTERY PARK PLAZA
NEW YORK, NEW YORK 10004
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WRITER'S DIRECT DIAL
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TELEPHONE: (212) 574-1200
FACSIMILE: (212) 480-8421
WWW.SEWKIS.COM
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901 K STREET, NW
WASHINGTON, D.C. 20001
TELEPHONE: (202) 737-8833
FACSIMILE: (202) 737-5184
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VIA EDGAR
Cecilia Blye Chief, Office of Global Security Risk
Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street N.E. Washington, DC 20549 |
August 22, 2014
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Re:
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Paragon Shipping Inc.
Form 20-F for the Fiscal Year Ended December 31, 2013 Filed March 27, 2014 File No. 1-33655 |
2. | Please discuss the materiality of your contacts with Cuba, Sudan and Syria described in response to the comment above and whether those contacts constitute a material investment risk for your security holders. You should address materiality in quantitative terms, including the approximate dollar amounts of any associated revenues, assets, and liabilities for the last three fiscal years and the subsequent interim period. Also, address materiality in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company's reputation and share value. Various state and municipal governments, universities, and other investors have proposed or adopted divestment or similar initiatives regarding investment in companies that do business with U.S.-designated state sponsors of terrorism. You should address the potential impact of the investor sentiment evidenced by such actions directed toward companies that have operations associated with Cuba, Sudan and Syria. |
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SEWARD & KISSEL LLP
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By:
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/s/ Edward S. Horton
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Edward S. Horton
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cc:
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Robert Perri
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Chief Financial Officer
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Paragon Shipping Inc.
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15 Karamanli Avenue
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GR 166 73
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Voula
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Greece
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Re:
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Paragon Shipping Inc.
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August 22, 2014
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The Company is responsible for the adequacy and accuracy of the disclosure in this filing;
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Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and
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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.
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Very truly yours,
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PARAGON SHIPPING INC.
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By:
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/s/ Robert Perri
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Name:
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Robert Perri
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Title:
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Chief Financial Officer
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