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                              SEWARD & KISSEL LLP
                             ONE BATTERY PARK PLAZA
                            NEW YORK, NEW YORK 10004

                           TELEPHONE: (212) 574-1200
                           Facsimile: (212) 480-8421
                                 www.sewkis.com

                                                   September 18, 2007

VIA EDGAR

Mr. Michael Fay
Division of Corporation Finance
Securities and Exchange Commission
CF/AD5
100 F Street, N.E.
Washington, D.C. 20549

               Re:  TOP Tankers Inc. Form 20-F for Fiscal Year
               Ended December 31, 2006 (File No. 000-50859)

Dear Mr. Fay:

          This letter responds to follow-on comments of the staff (the "Staff")
of the Securities and Exchange Commission (the "SEC") to the Annual Report on
Form 20-F for the fiscal year ended December 31, 2006 ("Form 20-F") of TOP
Tankers Inc. (the "Company") filed April 20, 2007, as provided in a letter to
Evangelos J. Pistiolis, the Company's President and Chief Executive Officer,
dated September 5, 2007 (the "September Comment Letter"). The Staff had
initially provided comment to the Company's Form 20-F in a letter dated August
2, 2007 (the "August Comment Letter"), and the Company responded to the August
Comment Letter in correspondence filed on EDGAR on August 24, 2007 (the "Initial
Response Letter"). This letter sets forth the Company's responses to the Staff's
comments.

          As discussed with the Staff, we are providing the following appendices
to this letter supplementally:

          Appendix B,
          Appendix C(i), (ii) and (iii),
          Appendix D.

          For your convenience, the Staff's comments have been restated in their
entirety,  with the  responses to each comment set forth  immediately  under the
comment.

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

Item 3.  Key Information
Selected Financial Information

Comment 1.     Refer to your response to our prior comment 1. You state EBITDA
               is useful because it is used by financial analysts and because it
               facilitates operating performance comparisons from period to
               period and from company to company by backing out differences
               caused by variations in capital structure, tax positions, and
               facilities and equipment. With regard to its use by financial
               analysts, this is not a substantive reason specific to you that
               justifies usefulness. Refer to footnote 44 of FR-65. With regard
               to facilitating operating performance comparisons from period to
               period, it does not appear that you have explained how this
               measure is useful. If your implication is that EBITDA facilitates
               period to period comparisons by eliminating certain variances in
               items eliminated, we caution you that a non-GAAP measure should
               never be used in an attempt to smooth earnings. With regard to
               facilitating operating performance comparisons from company to
               company, it is not clear why you believe it is useful for
               investors to ignore factors such as capital structure, tax
               positions, and facilities and equipment when making such
               comparisons. Additionally, interest and tax expenses we already
               excluded from operating income, a GAAP measure, so it is not
               clear why an alternative measure is necessary to exclude such
               amounts. Based on your response, you have not provided
               substantive justification as to the usefulness of EBITDA to
               investors. Therefore, please revise your filings to eliminate
               presentation of this non-GAAP measure.

Response:      The Company will refrain from including EBITDA in future filings
               on Form 20F.

Consolidated Statements of Cash Flows
-------------------------------------

Comment 2.     Refer to your response to our prior comment number 3. Please
               consider adding disclosure consistent with your response that
               explains why restricted cash is presented as both an investing
               and financing activity in the statements of cash flows as
               applicable.

Response:      The Company will add such disclosure in future filings.

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

Comment 3.     We note your responses to our prior comment numbers 4, 5, and 6
               and appreciate your detailed responses. You state that upon
               survey or inspection of your vessels, you incur costs for tasks
               necessary to satisfy requirements of the vessel's classification
               society and that you capitalize such costs. The fact that certain
               repair and maintenance activities are determined to be necessary
               as a result of regulatory inspections should not affect how you
               account for the associated costs. While you deem these costs to
               be "non-routine" and integral to satisfying inspection
               requirements, in large part they appear to be incurred for
               repairs and maintenance that do not appreciably extend the useful
               life, increase the earning capacity, or improve the efficiency of
               the vessels, but rather allow the vessels to continue to be
               operated in their current capacity. In this regard, it appears
               these costs do not qualify for capitalization but rather should
               be expensed as incurred in accordance with your accounting policy
               for repairs and maintenance costs, which states that all repairs
               and maintenance costs are expensed as incurred. Based on the cost
               categories outlined in your response to our prior comment 6,
               steelworks, coating of tanks and other components, piping and
               valves, and machinery and electrical works costs do not generally
               appear eligible for capitalization. With regard to the "other
               expenses" category, "oil sludge," "sewage and garbage removal,"
               "temporary lighting," "telephone and ventilation services," and
               "cleaning of debris" also do not appear eligible for
               capitalization. We believe you should amend your Form 20-F for
               the year ended December 31, 2006 and subsequent filings, as
               appropriate, to restate your financial statements to expense when
               incurred the costs indicated in this comment that had been
               previously capitalized.

Response:      The Company respectfully disagrees with the Staff's assessment
               that drydocking costs (also referred to herein as Planned Major
               Maintenance Activities or PMMA) should be expensed when incurred
               rather than deferred.

               Survey processes for tankers are made up of integral steps set
               out by the International Maritime Organization ("IMO") and Class
               Societies to promote safety of life at sea, to certify the
               vessels' seaworthiness, to protect the environment, as well as to
               regulate all aspects of a vessel's construction and operation.
               IMO requirements are adopted by flag administrations which in
               turn delegate the implemenation and issuance of the relevant
               certificates to the classification societies.

               As discussed below, drydocking occurs in connection with class
               and statutory surveys required by a vessel's classification
               society and flag. Drydocking is a mandatory step that must be
               undertaken in order to satisfy statutory requirements by the IMO
               and to obtain or continue a vessel's class certification. Without
               the above required certifications, both class and statutory, a
               vessel is not able to operate in trade. Therefore, drydocking is
               directly analogous to airframe and aircraft engine overhauls
               required by civil air regulations at specific maximum periodic
               intervals to recertify that the airframe or engine is completely
               airworthy.(1) The Airline Guide , as amended in September 2006 by
               FASB Staff Position FSP AUG AIR-1 ("FSP AIR"), notes the
               principal source of guidance on the accounting for PMMA is the
               Airline Guide. FSP AIR permits three alternative methods of
               accounting for PMMA as follows: (1) direct expense, (2) built-in
               overhaul and (3) deferral.(2) We understand during the
               deliberation of the FSP AIR, the Financial Accounting Standards
               Board ("FASB") recognized in its meetings that entities in the
               shipping industry typically account for PMMA using the deferral
               method.(3) FSP AIR further notes the guidance in the FSP is
               applicable to entities in all industries.(4)

----------
(1)  AICPA Industry Audit Guide, Audits of Airlines, With Conforming Changes as
     of May 2005, Section 3.64. This guide will be referred to hereinafter as
     "Airline Guide." It is widely recognized that the Airline Guide is often
     applied by analogy by companies in other industries. See, e.g., FASB Staff
     Position FSP AUG-AIR-1, paragraph 4 ("The guidance in this FSP is
     applicable to entities in all industries").

(2)  FSP AUG AIR-1 amended the Airline Guide to delete, effective beginning with
     the first fiscal year beginning after December 15, 2006, the
     accrual-in-advance method for PMMAs.

(3)  Discussed during Board Meeting of the Financial Accounting Standards
     Board--Planned Major Maintenance Activities Agenda Request, March 8, 2006.

(4)  FASB Staff Position FSP AUG-AIR-1, paragraph 4.
<PAGE>

               Drydocking costs may be deferred because they are analogous to
               the airframe and engine overhauls discussed in the Airline Guide.
               The Federal Aviation Administration ("FAA") has established
               overhaul cycles for each airframe and engine component in an
               effort to prevent potential hazards and to ensure transportation
               safety.(5) For accounting purposes, airframe and aircraft engine
               overhauls encompass all inspections or replacements of major
               components, which the civil air regulations require at specific
               maximum periodic intervals to recertify that the airframe or
               engine is completely airworthy(6). An overhaul does not include,
               however, the cost of routine replacement of minor parts.(7) Under
               the Airline Guide, carriers should adopt an accounting method
               that recognizes overhaul expenses in the appropriate period.(8)
               One acceptable method contained in FSP AIR and the Airline Guide
               is the deferral method, under which the actual cost of each
               overhaul is deferred and amortized to the next overhaul.(9)

               In accordance with FSP AIR, we believe drydocking costs may be
               deferred as they are directly analogous to the airframe and
               engine overhauls discussed in the Airline Guide. With very few
               exceptions, vessels are drydocked only in connection with
               statutory and class requirements and the necessary overhauling
               performed needs to comply with classification standards and
               statutory requirements in order to obtain or maintain the
               relevant certificates. As with aircraft, which cannot operate
               commercially without being recertified by civil aviation
               authorities, a cargo vessel (regardless of whether it is a
               tanker, drybulk carrier or container vessel) is not considered
               seaworthy, cannot be insured and therefore cannot operate unless
               it is certified as being "in class" by the applicable
               classification society and in compliance with flag statutory
               requirements.(10)

----------
(5)  Airline Guide, Section 3.63.

(6)  Airline Guide, Section 3.64.

(7)  Id. Also excluded from overhauls are costs accounted for as restoration of
     assets, such as extraordinary costs associated with the renewal of major
     structural parts beyond the scope of normal periodic overhauls, and other
     costs with a life span similar to the depreciable service life of the
     related airframe or aircraft engine.

(8)  Airline Guide, Section 3.69.

(9)  Id. As discussed below, the use of the deferral method for drydocking
     expenses has been adopted by almost every listed shipping company.

(10) The International Maritime Organization ("IMO") in its regulation of the
     Safety Of Life At Sea ("SOLAS), Regulation 10.a(v), specifically defines
     the mandatory survey Dry-Dock ("DD") cycles of all cargo vessels. A copy of
     the regulation is attached to this letter as Appendix A. Flag
     administrations have approved classification societies that are responsible
     for the implementation of these survey requirements.
<PAGE>

               Each classification society imposes its own requirements that
               must be fulfilled in order for the society to issue a
               classification certificate to a vessel. With respect to
               drydocking requirements, these classification societies'
               requirements coincide with the International Maritime
               Organization's SOLAS regulation. These requirements concern all
               PMMAs, including steelworks, coating of tanks, piping and valves,
               etc.(11) These activities and tasks are performed during
               drydocking only because they are required for classification
               purposes. Unless these tasks and activities are performed
               completely and to the full satisfaction of the classification
               society, the vessel could not achieve its class certificate.

               The International Association of Classification Societies (IACS)
               has developed a set of common rules for the vessels' construction
               and periodical survey certification process. These common rules
               are attached in Appendix D. Each classification society has
               adjusted their requirements based on the IACS guidelines.

----------
(11) Attached as Appendix B are the survey requirements of one of the
     classification societies, Det Norske Veritas (DNV), which is currently the
     classification society for 12 of the Company's vessels. In addition,
     attached as Appendix C(i), C(ii) and C(iii), respectively, are Class Status
     Report, Survey Report and Condition Evaluation Report for the vessel
     Priceless, which underwent drydocking in 2006. (12) Airline Guide, Section
     3.64.

<PAGE>

               The Company, in accordance with the requirements set by its
               classification societies, has developed the following main
               drydock works categories, in order to better monitor each process
               and account for the relevant expenses accordingly. All of the
               following categories include all the works that are required by
               IACS Common Rules in sections Z10.1, titled "Hull Surveys of Oil
               Tankers" and Sections Z18-Z22,