SecProbe.io

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December 10, 2004

MAIL STOP 0511

Angeliki Frangou
Chairman of the Board, Chief Executive Officer and President
International Shipping Enterprises, Inc.
1225 Franklin Avenue, Suite 325
Garden City, New York 11530

      Re:	International Shipping Enterprises, Inc.
		Registration Statement on Form S-1
		File No. 333-119719
      Amended December 9, 2004

Dear Ms. Frangou:

      We have reviewed your amended filing and have the following
comments.  Where indicated, we think you should revise your
document
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note your response to our comment one.  The company states
in
the Use of Proceeds section that "[a]ny amounts not paid as
consideration to the sellers of the target business may be used to
finance operations of the target business or to effect other
acquisitions."  Please reconcile this statement with the
disclosure
in the MD&A section that states "[t]o the extent that our capital
stock is used in whole or in part as consideration to effect a
business combination, the proceeds held in the trust fund as well
as
any other net proceeds not expended will be used to finance the
operations of the target business."
It would appear that to the extent that the company uses
stock/cash
or a combination of the two, any net proceeds would be used to
finance the operations of the target business.  Please revise the
registration statement accordingly.

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Questions on disclosure issues may be directed to Bill
Underhill at (202) 942-2953.

						Sincerely,

						John Reynolds, Assistant Director
						Office of Emerging Growth Companies

cc:	Scott M. Miller, Esq.
	Fax: (212) 809-5449

      Jeff Gallant, Esq.
	Fax: (212) 818-8881

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International Shipping Enterprises, Inc.
December 10, 2004
Page 2

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