SEC Company Response from TOP SHIPS INC. (TOPS) (CIK 0001296484) (TOPS) — Jan 14, 2020
TOP SHIPS INC. (TOPS) (CIK 0001296484)
Date: Jan. 14, 2020 · CIK: 0001296484 · Accession: 0000919574-20-000353
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File numbers found in text: 333-234744
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CORRESP
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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
901 K STREET, NW
WASHINGTON, D.C. 20001
TELEPHONE: (202) 737-8833
FACSIMILE: (202) 737-5184
January 14, 2020
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
100 F Street N.E.
Washington, D.C. 20549
Attn: Karina Dorin, Staff Attorney
Re:
TOP Ships Inc.
Amendment No. 2 to Registration Statement on Form F-1
Filed January 8, 2020
File No. 333-234744
Dear Ms. Dorin:
In response to discussions with the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the
Company’s registration statement on Form F-1 (the “Form F-1”) that was initially filed via EDGAR on November 18, 2019 and thereafter amended on December 27, 2019 and January 8, 2020, the Company has added disclosure to the Form F-1 relating to the
compensation of the directors and officers of the Company during fiscal year 2019. The Company has today filed via EDGAR this letter, together with its third amended Form F-1 (“Amendment No. 3”), which includes the added disclosure relating to
compensation on page 5 and certain other updates for the passage of time.
*********
If you have any questions or comments concerning this letter, please feel free to contact the undersigned at (212) 574-1223 or Evan
Preponis at (212) 574-1438.
Very truly yours,
SEWARD & KISSEL, LLP
By:
/s/ Gary J. Wolfe
Gary J. Wolfe
cc: Evangelos Pistiolis
TOP Ships Inc.