SecProbe.io

August 31, 2011
 Mr. Eirik Eide Chief Financial Officer Ship Finance International Limited Par-la-Ville Place
14 Par-la-Ville Road
Hamilton, HM 08, Bermuda
Re: Ship Finance International Limited
 Form 20-F for the Year Ended December 31, 2010
Filed March 25, 2011 File No. 001-32199

Dear Mr. Eide:
 We have reviewed your response dated August 15, 2011 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 ma y have additional comments.
            Form 20-F for the Year Ended December 31, 2010

 “Our vessels may call on ports lo cated in countries that are subj ect to restrictions…,” page 7

1. Please refer to comment 2 in our letter date d June 30, 2011.  Describe to us the types of
cargoes that your vessels have  carried into each of Ira n and Sudan since 2008, and the
nature of the operations of your drilling unit offshore Sudan in 2010.

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.

Mr. Eirik Eide Ship Finance International Limited August 31, 2011 Page 2

  In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d 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.

You may contact Amy Gedde s at 202-551-3304 or me at 202-551-3211 if you have
questions regarding comments on th e financial statements and rela ted matters.  Please contact
Sonia Bednarowski at 202-551-3666 if you have questions on legal matters.

 Sincerely,
   /s/ David R. Humphrey
David R. Humphrey
        A c c o u n t i n g  B r a n c h  C h i e f