SecProbe.io

June 9, 2011

Mr. Turid M. Sorensen Chief Financial Officer LOM Building 27 Reid Street Hamilton HM 11, Bermuda
Re: Nordic American Tanker Shipping Limited  Form 20-F
Filed April 21, 2011 File No. 001-13944
 Dear Mr. Sorensen:
 We have reviewed your filing 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

Risk Factors, page 5

 If our vessels call on ports located in countries that are subject to rest rictions im
 posed by the
U.S. or other governments, that could adversel y affect our reputation and the market for our
common stock, page 12.
1. In light of your statement that from time to tim e, vessels in your fleet call on ports in
countries identified by the U.S. government  as state sponsors of terrorism, please
represent to us that in future filings you w ill delete “If” from your risk factor heading,
so that it is clear from the heading that  your vessels do, in fact, call on ports in
countries that have been  designated as state sponsors of terrorism.

2. You state that your vessels ca ll on ports located in countries  identified by the U.S.
governm
ent as state sponsors of terrorism.  Pl ease represent to us that in future filings
you will revise your risk factor disclosure to  name the countries identified by the U.S.
government as state sponsors of terrorism to which you refer.

Mr. Turid M. Sorensen Nordic American Tanker Shippping Limited
June 9, 2010 Page 2

 In this regard, we note that Cuba, Iran, S udan, and Syria are identified by the U.S.
Departm
ent of State as state sponsors of terrorism, and are subject to U.S. economic
sanctions and export controls.  Your a nnual report does not in clude disclosure
regarding contacts with those c ountries.  Describe to us th e nature and extent of any
past, current, and anticipated contacts w ith Cuba, Iran, Sudan, and Syria, whether
through subsidiaries, or other di rect or indirect arrangement s, since your letters to us
dated February 6, 2009 and March 30, 2009.  Fu rther, you should describe to us any
goods, fees, or services you have provided  or anticipate providing, directly or
indirectly, to the referenced count ries, and any agreements, commercial
arrangements, or other contact s you have had, or intend to ha ve, directly or indirectly,
with the governments or en tities controlled by the governments of those countries.

3. Please discuss for us the materiality of any contacts with Cuba, Iran, Sudan, and Syria
you describe in response to the foregoi ng comm
ent, and whether those contacts
constitute a material investment risk for your security holders.  You should address
materiality in quantitative terms, incl uding the approximate dollar amounts of any
revenues, assets, and liabilities associated with each of th e referenced countries since
your prior letters.  Also, address materialit y in terms of qualitative factors that a
reasonable investor would deem import ant in making an investment decision,
including the potential impact of corpor ate activities upon a co mpany’s reputation
and share value.  As you know, variou s state and municipal governments,
universities, and other inve stors have proposed or adopted divestment or similar
initiatives regarding investment in compan ies that do business with U.S.-designated
state sponsors of terrorism.  Your materiality analysis should address the potential
impact of the investor sentiment evid enced by such actions directed toward
companies that have contacts with Cuba, Iran, Sudan, or Syria.

Item 5. Operating and Financial Review and Prospects, page 34

A. Operating Results, page 34

4. We note that voyage expenses are $0 for the year ended December 31, 2010, which is
a significant decrease from the amount  recognized during 2009 and 2008.  Please
explain to us, and revise your disclosure in future filings to explain why there were no
voyage expenses during 2010.  For example,  you disclose that voyage expenses
decreased by 100% to $0 in 2010 from $9 million in 2009 but you do not explain the reason(s) for the decrease.  Your response and revised disclosure should explain the
nature of any changes in the way your bus iness operated in 2010 as compared to 2009
and 2008 and explain any changes in the types of pooling arrangements and how
those arrangements are accounted fo r in your financial statements.

Mr. Turid M. Sorensen Nordic American Tanker Shippping Limited
June 9, 2010 Page 3

B. Liquidity and Capital Resources, page 37

5. Please revise your disclosure in future f ilings to include the approximate amount of
capital expenditures expected to be in curred in fiscal 2011, as you have incurred
significant amounts of capital expenditure s in the last two fiscal years.
 Tabular Disclosure of Contractual Obligations, page 39

6. We note from your balance sheet that as of December 31, 2010 there is a long-term
liability for deferred compensa tion in the amount of $8 milli on.  It appears that this
long-term liability should be included in  your table of contractual obligations in
accordance with Item 303(a)(5) of Regulation S-K.  Please advise or revise future
filings accordingly.
 Critical Accounting Estimates – Revenue Recognition, page 40

7. Please revise your disclosure in your criti cal accounting estimates section in future
filings to discuss how you account for revenu e attributable to vessels operating in
cooperative agreements, includ ing the recording of revenue on a gross versus net
basis.

Critical Accounting Estimates – Long-lived assets and impairments, page 40
8. From your disclosure of Industry Specific Risk Factors in Item 3.D, we note several
risk factors that discuss the volatility and un certainty of asset valu es of vessels.  In
this regard, we have also noted that (i ) asset values in th e shipping industry are
currently below their 10-year historical values; (ii) the de pendency and uncertainty of
credit availability to finance and expand operations has materially affected asset
values; and (iii) the market price for tankers  has declined significantly from levels
reached several years earlier and have re mained at relatively low levels.
Furthermore, some companies are burdened with legacy issues such as vessels purchased at values significantly above hi storical averages or commitments for
newbuildings at costs significantly above cu rrent market values.   For example, with
the contracts on two of your Suezmax newbuildings committed in November 2007 with delivery of one vessel in December 2010 and the delivery of the other at a
unknown future date, it is unclear if th e committed costs of these vessels will
significantly exceed their current market values.
In view of your continued decrease in operating and net income coupled with your
operating losses experienced in the last fiscal year and recent interim period as well as
the highly material amount of vessels that  represent in excess of  90% of your total
consolidated asset value, we  believe that the disclosu re in critical accounting
estimates should be significantly expanded to describe the specific factors and
conditions where you would record an impairme nt loss for such vessels.   In addition,
we suggest that you consider adding a tabl e summarizing the date of acquisition, the

Mr. Turid M. Sorensen Nordic American Tanker Shippping Limited
June 9, 2010 Page 4

purchase p
rice and carrying valu e of each vessel in your fleet  and identify within this
table those vessels whose estimated market values are less than their carrying values
as of the most recent year end.   Along w ith this table, please add disclosure below
the table of the aggregate market value and aggregate book value for those vessels
identified as having estimate d market values less than their carrying values.  This
additional disclosure will pr ovide investors with an i ndication of the estimated
magnitude of the potential aggregate impairme nt charge related to these vessels if you
decided to sell all of such vessels.
Audited Financial Statements
 Statement of Shareholders’ Equity, page F-5

9. We note that during the year ended December 31, 2009 you reduced Additional Paid-In Capital and increased Retained Earni ngs by $117,020 and described the transaction
as “accumulated dividend distribution defined as  return of capital.”  Please explain to
us the nature of this tran saction and tell us why you be lieve it is an appropriate
adjustment in 2009.  Also, please explain to us  and revise your notes to the financial
statements in future filings to explain why additional paid-in capital has been charged for cash dividends paid in 2008, 2009 and 2010.

Note 1. Business and Summary of  Si
 gnificant Accounting Policies

-Impairment of Long-Lived Assets, page F-8

10. We note your disclosure that  long-lived assets are requi red to be reviewed for
impairment whenever events or changes in circumstances indicate that the carrying amount of an asset may not be recoverable.   In light of the continued decrease in
operating and net income over the last few y ears and recognition of an operating loss
for the year ended December 31, 2010 and quarter ended March 31, 2011, please tell
us when you last performed an impairment  analysis on your vessels and provide us
the results of that analysis.

– Drydocking, page F-8

11. We note your disclosure that you follow the deferral method of accounting for
drydocking costs whereby actual costs incu rred are deferred and amortized on a
straight-line basis to the expected date of the next drydocking.  Please revise your
disclosure in future filings in the notes to the financial statements and in the Critical
Accounting Estimates section of  MD&A to provide a detaile d description of the types
of drydocking costs included in deferred drydocking costs and an affirmative
statement that the types of costs deferred are consistent in all periods presented.  If the
types of costs deferred are not consistent , provide a discussion of any changes in
types of costs deferred.

Mr. Turid M. Sorensen Nordic American Tanker Shippping Limited
June 9, 2010 Page 5

- Revenue and Expense Recognition, page F-8

12. We note your disclosure that a voyage is  deemed to commence upon the completion
of discharge of the vessel’s previous car go and is deemed to end upon the completion
of discharge of the current cargo.  Please note that recognition of voyage revenue
commencing upon the completion of discharge of the vessel's previous cargo is not considered to be in accordance with GAAP b ecause revenue is recognized in advance
of performance.  Please revise your policy to rec ognize revenue under ASC 605-20-
25, or alternatively, explain to us why you believe your revenue recognition policy is
appropriate (e.g. revenue is not recognized until a charter is agreed to with the
customer).

Note 8. Deposit on Contract, page F-14

13. We note your disclosure that as of December 31, 2010 you have $35.8 million
capitalized on your balance sheet related to the Nordic Galaxy which was not
delivered in August 2010 as expected becau se the vessel was not in deliverable
condition.  Please explain to us, and disclo se in future filings, why you believe the
$35.8 million amount is recoverable as of  December 31, 2010.  As part of your
response and revised disclosure, please tell us why you do not believe that a reserve is
necessary in light of the pending litigation.  Al so, in light of the fact that the agreed
total price at delivery was $90 million, please tell us and revise your disclosure to
explain why you believe it is not probable that a loss contingency existed as of
December 31, 2010.  See guidance in ASC 450-50-25.

Note 9. Other Non-Current Assets, page F-15

14. We note that as of December 31, 2010 you ha ve $22 million capitalized as “working
capital, cooperative arrangements.”  With a view toward expanded note disclosure,
please explain to us the nature of th ese costs and why you believe they are
appropriately capitalized at December 31, 2010.  In this regard, we note your
disclosure that the amount includes the value of bunkers on board the vessels at the
time of delivery to Gemini Tankers LLC.  Please explain to us why you believe it is
appropriate to capitalize these amounts on the vessels that are bei ng transferred to the
cooperation.  Also, please explain to us the nature of the amounts characterized as initial funding of $.2 million per vessel.

Note 10. Share-Based Compensation

– 2004 Stock Incentive Plan, page F-16

15. We note your disclosure that in Augus t 2009 stock options were cancelled in
exchange for a payment equal to the differen ce between the strike price of the options
and the closing price of $30.70 per share for the Company’s shares on the NYSE and
the compensation of $7.23 per option result ed in a cash outlay of $2.3 million for the

Mr. Turid M. Sorensen Nordic American Tanker Shippping Limited
June 9, 2010 Page 6

Com
pany, which decreased APIC.  Please te ll us if all 320,000 options that were
cancelled had vested by the time of cancella tion in August 2009.  If not, please tell us
how you accounted for the unvested options in accordance with ASC 718-20-35-7.
 Note 14.  Accrued Liabilities, page F-19

16. We note that as of December 31, 2010 you have $949,000 of accrued drydock expenses for Nordic Harrier.  In light of  your disclosure in Note 1 that you account
for drydock costs under the deferral method, please explain to us why you have accrued drydocking costs at December 31, 2010.   In this regard, we are unclear if
you are using the accrue in advance met hod which is no longer considered in
accordance with GAAP.

17. We note from your disclosure in Note 14 that accrued expenses are approximately
43% and 40% of total current liab ilities as of December 31, 2010 and 2009,
respectively.   Please revise your note in fu ture filings to separately disclose all
amounts greater than 5% of to tal current liabilities.  See Rule 5-02.20 of Regulation
S-X.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of  the United States.

Mr. Turid M. Sorensen Nordic American Tanker Shippping Limited June 9, 2010 Page 7

You may contact Claire Erla nger at (202) 551-3301 or Joe Foti at (202) 551-3816 if you
have questions regarding comments on the fina ncial statements and related matters.

Sincerely,

Linda Cvrkel Branch Chief
  Via Facsimile (441) 292-5962