January 17, 2020

Edward Coll
Chief Executive Officer
Pangaea Logistics Solutions, Ltd.
c/o Phoenix Bulk Carriers (US) LLC
109 Long Wharf
Newport, RI 02840

       Re: Pangaea Logistics Solutions Ltd.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed March 20, 2019
           Response Dated January 3, 2020
           File No. 1-36798

Dear Mr. Coll:

       We have reviewed your January 3, 2020 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in our
December 4, 2019 letter.

Form 10-K for Fiscal Year Ended December 31, 2018

Item 6. Selected Financial Data
Selected Data from the Consolidated Statements of Operations, page 39

1.    We note your response to comment 2. In your proposed revised disclosure,
you reconcile
      gross profit to net transportation and service revenue, a non-GAAP
measure. Since you
      do not present or define gross profit elsewhere in your filing, please
tell us and disclose
      how you calculate gross profit.
2.    Please revise to disclose income/(loss) from continuing operations per
common share and
      cash dividends declared per common share within Selected Financial Data.
Refer to
      Instruction 2 of the Instructions to Item 301 of Regulation S-K.
 Edward Coll
Pangaea Logistics Solutions, Ltd.
January 17, 2020
Page 2

       You may contact Yolanda Guobadia, Senior Staff Accountant, at (202)
551-3562 or
Sondra Snyder, Senior Staff Accountant, at (202) 551-3332 with any questions.



FirstName LastNameEdward Coll                           Sincerely,
Comapany NamePangaea Logistics Solutions, Ltd.
                                                        Division of Corporation
Finance
January 17, 2020 Page 2                                 Office of Energy &
Transportation
FirstName LastName