SEC Comment Letter for NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177) (NAT) — Sep 5, 2013
NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177)
Date: Sept. 5, 2013 · CIK: 0001000177 · Accession: 0000000000-13-048838
AI Filing Summary & Sentiment
File numbers found in text: 333-187400
Referenced dates: July 31, 2013
Letter
September 5 , 2013 Via E -mail Herbjǿrn Hansson Chief Executive Officer Nordic American Tankers Limited LOM Building 27 Reid Street Hamilton HM 11 Bermuda
Re: Nordic American Tankers Limited Amendment No. 1 to Registration Statement on Form F-3 Filed June 28 , 2013 Response dated August 23 , 2013 File No. 333-187400
Dear Mr. Han sson:
We have reviewed your response to our letter dated July 31, 2013 and have the following additional comment.
Exhibit 5.1
1. We note your response to prior comment 1. Please provide us with the legal basis for the proposed revised disclosure in either version of counsel’s opinion included in your response letter. In doing so, please refer to the jurisdictional provisions of the federal securities laws an d any applicable case law in support of the inclusion of this language. Please also have counsel explain to us why this language does not explicitly or implicitly limit and condition reliance by purchasers in the offering. Otherwise, please have counsel remove this language in the last paragraph of the opinion.
Please contact J. Nolan McWilliams at (202) 551 -3217 or me at (202) 551 -3469 with any questions you may have .
Sincerely,
/s/ Justin Dobbie
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September 5 , 2013
Via E -mail
Herbjǿrn Hansson
Chief Executive Officer
Nordic American Tankers Limited
LOM Building
27 Reid Street
Hamilton HM 11
Bermuda
Re: Nordic American Tankers Limited
Amendment No. 1 to Registration Statement on Form F-3
Filed June 28 , 2013
Response dated August 23 , 2013
File No. 333-187400
Dear Mr. Han sson:
We have reviewed your response to our letter dated July 31, 2013 and have the following
additional comment.
Exhibit 5.1
1. We note your response to prior comment 1. Please provide us with the legal basis for the
proposed revised disclosure in either version of counsel’s opinion included in your
response letter. In doing so, please refer to the jurisdictional provisions of the federal
securities laws an d any applicable case law in support of the inclusion of this language.
Please also have counsel explain to us why this language does not explicitly or implicitly
limit and condition reliance by purchasers in the offering. Otherwise, please have
counsel remove this language in the last paragraph of the opinion.
Please contact J. Nolan McWilliams at (202) 551 -3217 or me at (202) 551 -3469 with any
questions you may have .
Sincerely,
/s/ Justin Dobbie
Justin Dobbie
Legal Branch Chief
cc: Gary J. Wolfe, Esq.
Seward & Kissel