December 10, 2018

Gregory Zikos
Chief Financial Officer
Costamare Inc.
7 rue du Cabian
MC 98000 Monaco

       Re: Costamare Inc.
           Form 20-F for the Year Ended December 31, 2017
           Filed February 27, 2018
           Form 6-K for the Period Ended September 30, 2018
           Furnished October 24, 2018
           File No. 001-34934

Dear Mr. Zikos:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 6-K furnished October 24, 2018

Exhibit 99.1 Earnings Release, page 1

1.    We note that in your earnings release furnished on October 24, 2018 as
Exhibit 99.1 of
      Form 6-K, you disclose adjusted net income available to common
stockholders and
      adjusted net income available to common stockholders per share. Please
revise to include
      disclosure of the most directly comparable GAAP measure, net income. See
Regulation
      G.
 Gregory Zikos
FirstName LastNameGregory Zikos
Costamare Inc.
Comapany10, 2018
December NameCostamare Inc.
Page 2
December 10, 2018 Page 2
FirstName LastName
Form 20-F for the Year Ended December 31, 2017

Item 5. Operating and Financial review and Prospects
Critical Accounting Policies
Vessel Impairment, page 86

2.       We note your disclosure on page 86 that an internal analysis, which
used a discounted
         cash flow model utilizing inputs and assumptions based on market
observations as of
         December 31, 2017, suggests that 29 of your 52 vessels in the water
may have current
         market values below their carrying value. We also note that you have
disclosed a table of
         those vessels and the aggregate amount by which the carrying value
exceeds the market
         value. In light of the fact that market values appear to be based on
discounted cash flows
         which are based on assumptions which are highly subjective, please
tell us what
         consideration was given to utilizing charter free shipbroker values,
adjusted for existing
         time charters, to determine market value. Also, we note that the first
paragraph on page
         86 appears to indicate that you take into consideration third party
valuations in
         determining fair value of the vessels. As it relates to the 7 vessels
that failed Step 1 of the
         impairment analysis in 2017, please clarify for us how fair value is
determined in Step 2
         of the impairment analysis. Additionally, with respect to the
underlying undiscounted
         cash flow portion of the analysis, please:
           Confirm that a growth rate is not applied to estimated future
inflows for charter free
             days.
           Considering the depressed rates in most recent years, please
elaborate on your basis
             that the ten year historical average rates represent a full
shipping cycle. As part of
             your response, please provide us with a chart showing the ten year
shipping cycle, and
             what you have considered as outliers to be removed from the
analysis.
           Tell us whether a useful life of 30 years is applied throughout the
estimated future cash
             flows and why, when during the year ended December 31, 2017 and
the subsequent
             period ended September 30, 2018 several dispositions for
demolition have been taking
             place prior to the 30 year mark.
 Gregory Zikos
Costamare Inc.
December 10, 2018
Page 3

       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Effie Simpson at (202) 551-3346 or Claire Erlanger at
(202) 551-3301
with any questions.



                                                          Sincerely,
FirstName LastNameGregory Zikos
                                                          Division of
Corporation Finance
Comapany NameCostamare Inc.
                                                          Office of
Transportation and Leisure
December 10, 2018 Page 3
cc:       A. Gabrieliedes
FirstName LastName