SecProbe.io

CORRESP
1
filename1.htm

    d978924_corresp.htm

    March 30,
2009

      VIA EDGAR

                Cecilia D. Blye, Esq.

                Chief,
      Office of Global Security Risk

                United
      States Securities and Exchange Commission

                100
      F Street N.E.

                Washington,
      DC  20549-5546

                Re:

                Nordic American Tanker Shipping Limited

                Form
      20-F for the Fiscal Year Ended December 31, 2007

                Filed
      May 9, 2008

                File
      No. 1-13944

      Dear Ms. Blye:

      We
represent Nordic American Tanker Shipping Limited (the
“Company”).  By letter dated February 19, 2009, the Staff of the
Securities and Exchange Commission (the “Staff”) provided a further comment to
the Company’s Annual Report on Form 20-F for the Fiscal Year ended December 31,
2007 (the “Annual Report”).  The Company’s response, together with the
Staff’s request, is set forth below.

                1.

                We
      note your response to our prior comment 2.  Please provide us
      with information that explains how the fact that the port calls made to
      Sudan by your ships in 2007 and 2008 reflect only 5% of the total port
      calls made by all your ships correlates with, and supports, your
      conclusion that the revenues related to your contacts with Sudan are
      quantitatively immaterial.

      As
discussed in the Company’s response of February 6, 2009, the Company operates
eleven of its twelve trading vessels in cooperative spot market arrangements
with vessels owned by third parties. These arrangements are managed and operated
by the Swedish group, Stena Bulk AB and by Frontline Management Limited, both of
which are third party administrators. These administrators have the
responsibility for the commercial management of the participating vessels,
including marketing, chartering, operating and bunker (fuel oil) purchasing for
the vessels. As a result, the administrators, not the Company, choose the ports
of call for the vessels.

      Secondarily,
the earnings of all of the vessels in the pool are aggregated and divided
according to the relative performance capabilities of each vessel and the actual
earning days each vessel was available during the period, which means that the
Company does not receive revenues that are identified as having accrued from any
specific voyage, even if one of the Company’s vessels was involved in that
voyage.  As a result, the Company does not receive revenues identified
to the calls on Marsa Bashayer, other than its share of the revenues calculated
across the group of vessels managed by the administrator as a whole during the
period.

      Finally,
the Company does not pay expenses related to the calls on Marsa Bashayer,
including payments to Sudanese port authorities for docking and other services,
other than its share of the expenses calculated across the vessels in the pool
as a whole during the period.

      In
conclusion, as (i) the contractual counterparties for the Company’s vessels are
non-Sudanese pool operators, (ii) the Company does not direct the port calls of
these entities, (iii) the Company does not receive revenues identified to the
Sudanese port calls, and (iv) the Company does not pay expenses directly related
to the Sudanese port calls, the Company does not believe that it does business
with Sudan.

      Accordingly,
the Company believes that qualitatively and quantitatively the level of its
contacts with Sudan poses no material risk to its investors.

      *                              *                                *                                *

      The
Company understands that it is responsible for the adequacy and accuracy of the
disclosure in its filing; Staff comments or changes to disclosure 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 federal
securities laws of the United States.

      Please
feel free to contact the undersigned at (212) 574-1223, or Charles Cotter of
this office at (212) 574-1440, with any questions or comments.

                  Very truly yours,

                  SEWARD
      & KISSEL LLP

                  /s/ Gary J. Wolfe

                  by:  Gary
      J. Wolfe

                  cc:

                  Max Webb, Esq.

                  Assistant
      Director

                  Division
      of Corporation Finance

                  Pradip
      Bhaumik, Esq.

                  Special
      Counsel

                  Division
      of Corporation Finance

                  Herbjørn
      Hansson

                  Chief
      Executive Officer

                  Nordic
      American Tanker Shipping Limited