SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
CF/AD5
100 F STREET, NE
WASHINGTON, D.C. 20549-3561

       DIVISION OF
CORPORATION FINANCE

        October 18, 2007

Via Mail and Fax

Stamatios N. Tsantanis
Chief Financial Officer
Top Tankers Inc.
1 Vassilissis Sofias and Meg.
Alexandrou Street, 15124
Maroussi, Greece

 RE:  Top Tankers Inc.
   Form 20-F for the Year Ended December 31, 2006
   File Number: 000-50859

Dear Mr. Tsantanis:

 We have reviewed your corresponden ce dated September 18, 2007, and have the
following comment.  We believe you should amend your filings as indicated in our
comment.  If you disagree, we will consider you r explanation as to why an amendment is
not necessary.  Please be as detailed as neces sary in your explanation.  Please file your
response to our comment via EDGAR, under the label “corresp,” within 10 business days
from the date of this letter.

Form 20-F for the Year Ended December 31, 2006

Notes to Consolidated Financial Statements
Note 2. Significant Accounting Policies
(m) Accounting for Dry-Docking Costs

1. We note your response to our prior comment number 3.  The fact that you have begun
labeling these costs as Planned Major Maintenance Activities (or “PMMA”) in
response to our comments does not change the underlying natu re of the large majority
of the costs that you have cap italized as drydocking; they  are expenditures incurred
for repair and maintenance that do not apprec iably extend the useful life, increase the
earning capacity, or improve the efficiency of  vessels, but rather allow vessels to
continue to be operated in their current capacity.  With respect to your reference to
FSP AUGAIR-1, we believe the guidance was in tended solely to eliminate use of the
accrue-in-advance method.  While we understand your effort to analogize to the AICPA Airline Guide and its reference to th e deferral method, it is important to note

Top Tankers Inc.
October 18, 2007
Page 2
that the deferral method is ra rely used in practice by air lines.  In fact, the largest
airlines expense maintenance as incu rred and do not use the deferral method.
Because direct expensing, rather than defe rral, is the predominant method used in
practice in the airline indus try, we do not find your analogy to the Airline Guide’s
deferral method to be a compelling reason to allow you to capitalize non-betterment
repair and maintenance costs incurred duri ng drydocking.  In a ddition, your practice
of capitalizing these repair and maintenance costs is problematic because it implies that estimated useful lives assigned to a portion of your vessels’ initial costs were
greater than they should have been (built-in overhaul method) .  It is also problematic
because it results in inconsistent treatmen t by you of repair and maintenance costs,
with some being capitalized and some bei ng expensed depending solely on whether
the costs were performed before or afte r being noted as necessary by a drydocking
inspection.  We do not object to you capitalizing the actual  cost of the regulatory
inspection and the drydocking itself (i.e., the cost to put the ship  in the dry dock and
have it stored there temporarily).  However, we continue to believe repair and maintenance costs that are not betterment s do not qualify for deferral but rather
should be expensed as incu rred in accordance with your accounting policy for repair
and maintenance costs, which states that  all repair and maintenance costs are
expensed as incurred.  We believe you should amend your Form 20-F for the year
ended December 31, 2006 and subsequent fili ngs, as appropriate, to restate your
financial statements to expense, rather  than defer and amortize, repair and
maintenance costs incurred during drydockings  in conformity with your repair and
maintenance costs accounting policy.

  You may contact Doug Jones at 202-551-3309 or Lyn Shenk at 202-551-3816
with any questions.  You may also contact me at 202-551-3812.

 Sincerely,

 Michael Fay
 Accounting Branch Chief

cc: Gary J. Wolfe, Seward & Kissel LLP