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SEC Comment Letter for SFL Corp Ltd. (SFL) (CIK 0001289877) (SFL) — Aug 1, 2012

SFL Corp Ltd. (SFL) (CIK 0001289877)
Date: Aug. 1, 2012 · CIK: 0001289877 · Accession: 0000000000-12-041296

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
August 1, 2012
Author
/s/ David R. Humphrey
Form
UPLOAD
Company
SFL Corp Ltd. (SFL) (CIK 0001289877)

Letter

August 1, 2012 Mr. Harald Gurvin, 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, 2011 Filed April 27, 2012 File No. 001 -32199

Dear Mr. Gurvin :

We have completed our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with resp ect to the company or 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 la ws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing 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

Show Raw Text
August 1, 2012

Mr. Harald Gurvin, 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, 2011
Filed April 27, 2012
File No. 001 -32199

Dear Mr. Gurvin :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with resp ect to the company or 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 la ws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing 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
Accounting Branch Chief