SEC Comment Letter for SFL Corp Ltd. (SFL) (CIK 0001289877) (SFL) — Sep 13, 2011

SFL Corp Ltd. (SFL) (CIK 0001289877)
Date: Sept. 13, 2011 · CIK: 0001289877 · Accession: 0000000000-11-054645

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File numbers found in text: 001-32199

Date

September 13, 2011

Author

A c c o u n t i n g B r a n c h C h i e f

Form

UPLOAD

Company

SFL Corp Ltd. (SFL) (CIK 0001289877)

Letter

September 13, 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 completed our review of your f iling. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or th e filing and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

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

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September 13, 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 completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

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

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