CORRESP 1 filename1.htm JAVELIN CORRESP

JAVELIN Mortgage Investment Corp.

3001 Ocean Drive, Suite 201
Vero Beach, FL 32963


October 1, 2012

VIA EDGAR AND FAX


Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549


Re:   JAVELIN Mortgage Investment Corp.

Registration Statement on Form S-11 (File No. 333-182536)


Ladies and Gentlemen:


Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), JAVELIN Mortgage Investment Corp. (the "Company"), requests that the effectiveness of the Registration Statement referenced above be accelerated so that the Registration Statement may become effective at 4:00 p.m. (Eastern Daylight Time) on October 2, 2012, or as soon as possible thereafter.


As requested the Company acknowledges that:


·

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosures in the filing; and

·

the Company may not assert the staff's comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.


Sincerely,


JAVELIN Mortgage Investment Corp.




/s/ James R. Mountain                     

James R. Mountain

Chief Financial Officer


cc: Michael McTiernan

Stacie Gorman