CORRESP 1 filename1.htm
FRONTLINE LTD.
Par-la-Ville Place, 14 Par-la-Ville Road
Hamilton, HM 08, Bermuda
November 30, 2022
VIA EDGAR

U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549

Re:
Frontline Ltd.
Registration Statement on Form F-4, as amended
Initially Filed September 14, 2022
File No. 333-267407

Ladies and Gentlemen:

Frontline Ltd. (the “Company”) hereby requests that the effectiveness of the above-captioned Registration Statement on Form F-4 initially filed with the U.S. Securities and Exchange Commission (the “Commission”) on September 14, 2022, as amended, be accelerated so that it will be made effective at 4:00 p.m. Eastern Daylight Time on December 2, 2022, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Seward & Kissel LLP, request by telephone that such Registration Statement be declared effective, pursuant to Rule 461(a) of the Securities Act of 1933, as amended (the “Act”).
 
The Company 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 Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company 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 Company is aware of its obligations under the Act.

Please contact Keith J. Billotti of Seward & Kissel LLP at (212) 574-1274, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.


   
Sincerely,
  
       
   
FRONTLINE LTD.
  
       
     
By:
/s/ Lars H. Barstad
  
     
Name:
Lars H. Barstad
  
     
Title:
Principal Executive Officer