SEC Comment Letter for TOP SHIPS INC. (TOPS) (CIK 0001296484) (TOPS) — Jan 6, 2020
TOP SHIPS INC. (TOPS) (CIK 0001296484)
Date: Jan. 6, 2020 · CIK: 0001296484 · Accession: 0000000000-20-000109
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-234744
Letter
January 6, 2020 Evangelos J. Pistiolis Chief Executive Officer TOP Ships Inc. 1 Vas. Sofias and Meg. Alexandrou Str. 15124 Maroussi, Greece Re:TOP Ships Inc. Amendment No. 1 to Registration Statement on Form F-1 Filed December 27, 2019 File No. 333-234744 Dear Mr. Pistiolis: We have reviewed your amended registration statement 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 by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 13, 2019 letter. Amendment No. 1 to Form F-1 General 1.We note your response to prior comment 3. Please revise the prospectus to state clearly whether you intend for the exclusive forum provision to apply to actions arising under U.S. federal securities laws.
FirstName LastNameEvangelos J. Pistiolis Comapany NameTOP Ships Inc. January 6, 2020 Page 2 FirstName LastName Evangelos J. Pistiolis TOP Ships Inc. January 6, 2020 Page 2 Please contact Karina Dorin, Staff Attorney, at (202) 551-3763 or, in her absence, Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Gary Wolfe
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January 6, 2020
Evangelos J. Pistiolis
Chief Executive Officer
TOP Ships Inc.
1 Vas. Sofias and Meg. Alexandrou Str.
15124 Maroussi, Greece
Re:TOP Ships Inc.
Amendment No. 1 to Registration Statement on Form F-1
Filed December 27, 2019
File No. 333-234744
Dear Mr. Pistiolis:
We have reviewed your amended registration statement 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 by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our December 13, 2019 letter.
Amendment No. 1 to Form F-1
General
1.We note your response to prior comment 3. Please revise the prospectus to state clearly
whether you intend for the exclusive forum provision to apply to actions arising under
U.S. federal securities laws.
FirstName LastNameEvangelos J. Pistiolis
Comapany NameTOP Ships Inc.
January 6, 2020 Page 2
FirstName LastName
Evangelos J. Pistiolis
TOP Ships Inc.
January 6, 2020
Page 2
Please contact Karina Dorin, Staff Attorney, at (202) 551-3763 or, in her absence,
Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Gary Wolfe