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Acceleration Request Letter

[Letterhead of NCL]

October 12, 2005

Securities and Exchange Commission

Division of Corporation Finance

Station Place

100 F Street, N.E.

Washington, D.C. 20549-0306

    Re:

    NCL Corporation Ltd. Registration Statement on Form F-4

(File No. 333-128780)

Dear Sir or Madam:

     On behalf of NCL Corporation Ltd. and in accordance with Rule 461 of the Securities Act of
1933, as amended, I hereby request the acceleration of the effective date of the above-referenced
registration statement so that such registration statement, as amended, is declared effective at
3:00 p.m., Eastern Standard Time, on October 14, 2005 or as soon as practicable
thereafter.

     In connection with this request for the acceleration of the effective date of the Registration
Statement, we acknowledge that:

     (i) should the Securities and Exchange Commission (the “Commission”) or the
staff, acting pursuant to delegated authority, declare the Registration Statement effective,
it does not foreclose the Commission from taking any action with respect to the Registration
Statement;

     (ii) the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not relieve the
registrant from its full responsibility for the adequacy and accuracy of the disclosure
in the Registration Statement; and

     (iii) the registrant may not assert the declaration of effectiveness as a defense in
any proceeding initiated by the Commission or any person under the federal securities laws
of the United States.

    Very truly yours,

NCL Corporation Ltd.

    By:
    /s/ Mark E. Warren

    Name:
    Mark E. Warren

    Title:
    Executive Vice President and
General Counsel