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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

Date
January 14, 2020
Author
Gary J. Wolfe
Form
CORRESP
Company
TOP SHIPS INC. (TOPS) (CIK 0001296484)

Letter

Division of Corporation Finance Office of Energy & Transportation 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

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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.