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Writer’s Direct Dial: (212) 225-2038

E-Mail: skang@cgsh.com

November 18, 2004

CONFIDENTIAL TREATMENT REQUESTED

BY HAND DELIVERY

Paul M. Dudek, Esq.

Office of International Corporate Finance

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

    Re:

    NCL Corporation Ltd.

Registration Statement on Form F-4

Dear Mr. Dudek:

     Please find enclosed on behalf of our client, NCL Corporation Ltd., a corporation organized
under the laws of Bermuda (the “Company”), ten copies of the Company’s draft Registration Statement
on Form F-4 (the “Registration Statement”) relating to the proposed exchange offer of the Company’s
10-5/8% senior notes due 2014 that were issued on July 15, 2004
for an equal amount of new 10-5/8% senior
notes due 2014.

     We hereby request confidential treatment of the Registration Statement and any supplemental
information or correspondence relating to this filing that we submit marked “Confidential Treatment
Requested.” This confidential treatment request is made under the Freedom of Information Act
pursuant to Section 200.83 of the Securities and Exchange Commission’s Rules of Practice. It is
our understanding that, pursuant to these Rules, (i) no

determination as to the merits of our request for confidential treatment will be made at this
time and (ii) if the staff receives a request for any of the documents subject to this request for
confidential treatment, we will be notified and provided with the opportunity to substantiate our
request for confidential treatment.

     Any questions relating to this request for confidential treatment and all notices issued with
respect thereto should be directed to me at (212) 225-2038 or Craig B. Brod at (212) 225-2650,
Cleary, Gottlieb, Steen & Hamilton, One Liberty Plaza, New York, New York 10006. I can also be
reached by facsimile at (212) 225-3999. The Company’s auditors, PricewaterhouseCoopers LLP, have
asked us to inform you that questions regarding the Company’s financial statements may also be
directed to Ann L. Payne at (954) 356-5902 or Bob Guido at (973) 236-5406.

     Please acknowledge receipt of this letter and the enclosures by stamping the enclosed copy of
this letter and returning it to our messenger.

    Very truly yours,

    /s/ S.K. Kang

    S. K. Kang

Enclosures

    cc:

    Mr. Barry D. Walters (w/o encl.)

(Freedom of Information Act Officer, Room 2307)

Lamarr B. Cooler

(Chief Financial Officer, NCL Corporation Ltd.)