July 8, 2019
Via E-mail
Konstantinos Konstantakopoulos
Chief Executive Officer
Costamare Inc.
7 rue de Gabian
MC 98000 Monaco

       Re:     Costamare Inc.
               Form 20-F for the Fiscal Year Ended December 31, 2018
               Filed March 7, 2019
               File No. 1-34934

Dear Mr. Konstantakopoulos:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comments.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comments, we 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.

Risk Factors, page 3
Our vessels may call on ports located in countries that are subject to
restrictions..., page 29

   1. You do not provide information about port calls to Sudan. Publicly
available information
      about some of the companies you identify as charterers indicates that
those companies have
      offices in, and shipping routes that include, Sudan. Sudan is designated
by the U.S.
      Department of State as a state sponsor of terrorism, and it is subject to
U.S. export controls.
      Please describe to us the nature and extent of any past, current, and
anticipated contacts with
      Sudan during the past three fiscal years and the subsequent interim
period, including contacts
      with Sudan's' government, whether through subsidiaries, charterers,
affiliates, or other direct
      or indirect arrangements. Discuss for us the materiality of any such
contacts, in quantitative
      terms and in terms of qualitative factors that a reasonable investor
would deem important in
      making an investment decision. Tell us the approximate dollar amounts of
any revenues,
      assets and liabilities associated with Sudan for the last three fiscal
years and the subsequent
      interim period.
 Konstantinos Konstantakopoulos
Costamare Inc.
July 8, 2019
Page 2

         We urge all persons who are responsible for the accuracy and adequacy
of the disclosure
in the filing to be certain that the filing includes the information the
Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its
management are
in possession of all facts relating to a company's disclosure, they are
responsible for the accuracy
and adequacy of the disclosures they have made.

      In responding to our comments, please provide a written statement from
the company
acknowledging that:

         the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

         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

         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.

        You may contact Jennifer Hardy, Special Counsel, at (202) 551-3767 or
me at (202) 551-
3470 if you have any questions about the comments or our review.

                                                             Sincerely,

                                                             /s/ Cecilia Blye

                                                             Cecilia Blye,
Chief
                                                             Office of Global
Security Risk

cc:      C. Scott Bennett, Esq.
         Cravath, Swaine & Moore LLP

         Anne Parker
         Assistant Director