SEC Company Response from TOP SHIPS INC. (TOPS) (CIK 0001296484) (TOPS) — Nov 16, 2004
TOP SHIPS INC. (TOPS) (CIK 0001296484)
Date: Nov. 16, 2004 · CIK: 0001296484 · Accession: 0000919574-04-003379
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-119806
Letter
Gary J. Wolfe Partner 212 574 1223 November 15, 2004 Katherine Hsu, Esq. Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street N.W. Washington, DC 20549
Re: Top Tankers, Inc. Reg No. 333-119806 ------------------
Dear Ms. Hsu:
You have inquired as to the filing by Top Tankers, Inc. (the "Company") of an opinion of counsel by way of a post-effective amendment to the captioned registration statement.
I have checked, and have confirmed that the failure to file an opinion of counsel pre-effectiveness was inadvertent. I was under the impression that our legal opinion had been filed pre-effectiveness, but the form of legal opinion contained Marshall Islands disclaimers that we had previously agreed with Michael Pressman of the Staff in an earlier transaction not to include. Even though the registration statement had not been reviewed, I was of the view that we should file an opinion in the proper form.
Accordingly, we drafted what I thought was a second legal opinion without the disclaimers and filed it post-effectiveness. That legal opinion covers the due authorization of the shares that were issued pursuant to the registration statement, and I confirm that the opinion relates to the time of effectiveness of the registration statement.
To the extent the Staff believes that a clarification shall be filed, we are happy to do so.
Please contact me with any questions.
Sincerely yours,
Gary J. Wolfe
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
[LETTERHEAD OF SEWARD & KISSEL LLP]
Gary J. Wolfe
Partner
212 574 1223
November 15, 2004
Katherine Hsu, Esq.
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street N.W.
Washington, DC 20549
Re: Top Tankers, Inc.
Reg No. 333-119806
------------------
Dear Ms. Hsu:
You have inquired as to the filing by Top Tankers, Inc. (the
"Company") of an opinion of counsel by way of a post-effective amendment to the
captioned registration statement.
I have checked, and have confirmed that the failure to file an opinion
of counsel pre-effectiveness was inadvertent. I was under the impression that
our legal opinion had been filed pre-effectiveness, but the form of legal
opinion contained Marshall Islands disclaimers that we had previously agreed
with Michael Pressman of the Staff in an earlier transaction not to include.
Even though the registration statement had not been reviewed, I was of the view
that we should file an opinion in the proper form.
Accordingly, we drafted what I thought was a second legal opinion
without the disclaimers and filed it post-effectiveness. That legal opinion
covers the due authorization of the shares that were issued pursuant to the
registration statement, and I confirm that the opinion relates to the time of
effectiveness of the registration statement.
To the extent the Staff believes that a clarification shall be filed,
we are happy to do so.
Please contact me with any questions.
Sincerely yours,
Gary J. Wolfe
23116.0001 #526500
</TEXT>
</DOCUMENT>