SCORPIO BULKERS INC.
9, Boulevard Charles III
MC 98000 Monaco
September 10, 2014
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
One Station Place
100 F Street N.E.
Washington, D.C. 20549-7010
Attention: Justin Dobbie, Legal Branch Chief
| Re: | Scorpio Bulkers Inc. |
Registration Statement on Form F-1 (No. 333-197949)
Ladies and Gentlemen:
The undersigned registrant hereby requests that the effectiveness of the above-captioned Registration Statement on Form F-1 filed with the U.S. Securities and Exchange Commission (the “Commission”) on August 7, 2014, as amended, be accelerated so that it will be made effective at 9:30 a.m. Eastern Daylight Time on September 12, 2014, or as soon thereafter as practicable, pursuant to Rule 461(a) of the Securities Act of 1933, as amended (the “Act”).
The undersigned registrant hereby acknowledges that (i) 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; (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the undersigned registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the undersigned registrant may not assert staff 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.
The undersigned registrant is aware of its obligations under the Act.
| Yours faithfully, | ||
| SCORPIO BULKERS INC. | ||
| By: | /s/ Hugh Baker | |
| Name: Hugh Baker Title: Chief Financial Officer | ||
Stifel, Nicolaus & Company, Incorporated
787 7th Avenue, 11th Floor
New York, NY 10019
Deutsche Bank Securities Inc.
60 Wall Street, 4th Floor
New York, New York 10005
Jefferies LLC
520 Madison Avenue
New York, New York 10022
September 10, 2014
VIA ELECTRONIC SUBMISSION
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
| Attn: | Justin Dobbie, Legal Branch Chief |
| Re: | Scorpio Bulkers Inc. |
Registration Statement Filed on Form F-1
Registration No. 333-197949
Ladies and Gentlemen:
Pursuant to Rule 460 under the Securities Act of 1933, we, as representatives of the several Underwriters, wish to advise you that we anticipate distributing approximately 2,250 copies of the Preliminary Prospectus to underwriters, dealers, institutions and others.
The undersigned have and will, and each participating underwriter and dealer has advised the undersigned that it has and will, comply with the provisions of SEC Release No. 33-4968 of the Act and Rule 15c2-8 of the Securities Exchange Act of 1934, as amended.
We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 9:30 a.m. Eastern Time, on Friday, September 12, 2014 or as soon thereafter as practicable.
| Very truly yours, | ||
| STIFEL, NICOLAUS & COMPANY, INCORPORATED | ||
| By: | /s/ Craig M. DeDomenico | |
| Name: Craig M. DeDomenico Title: Managing Director | ||
| DEUTSCHE BANK SECURITIES INC. | ||
| By: | /s/ Craig Fuehrer | |
| Name: Craig Fuehrer Title: Managing Director | ||
| By: | /s/ Warren F. Estey | |
| Name: Warren F. Estey Title: Managing Director | ||
| JEFFERIES LLC | ||
| By: | /s/ Jeffrey Pribor | |
| Name: Jeffrey Pribor Title: Mananging Director | ||