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SEC Company Response from Eagle Bulk Shipping Inc. (CIK 0001322439) — Jun 13, 2005

Eagle Bulk Shipping Inc. (CIK 0001322439)
Date: June 13, 2005 · CIK: 0001322439 · Accession: 0001047469-05-017104

AI Filing Summary & Sentiment

File numbers found in text: 333-123817

Referenced dates: June 6, 2005, May 31, 2005

Date
June 10, 2005
Author
Gary J. Wolfe
Form
CORRESP
Company
Eagle Bulk Shipping Inc. (CIK 0001322439)

Letter

Securities and Exchange Commission Division of Corporation Finance Registration Statement on Form S-1 Amendment No. 3 Filed June 6, 2005 File No. 333-123817

Re:

Dear Mr. Webb:

Further to my telephone conversation with Jeff Jaramillo of the Staff, enclosed is Exhibit 1 which was inadvertently omitted from my letter dated June 6, 2005 that accompanied Amendment No. 3 to the Registration Statement on Form S-1 filed by Eagle Bulk Shipping Inc. (the “Company”). Exhibit 1 relates to the Company’s response to comment 5 contained in the Staff’s comment letter dated May 31, 2005.

Please feel free to contact me at (212) 574-1223 or Robert Lustrin at (212) 574-1420 with any questions or comments.

Very
truly yours,
/s/
Gary J. Wolfe

Show Raw Text
CORRESP
1
filename1.htm

(212)
574-1223

June 10, 2005

Max A. Webb, Esq.

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-0305

  Re:

  Eagle
  Bulk Shipping Inc.

  Registration
  Statement on Form S-1

  Amendment
  No. 3

  Filed
  June 6, 2005

  File
  No. 333-123817

Dear Mr. Webb:

Further to my telephone conversation with Jeff
Jaramillo of the Staff, enclosed is Exhibit 1 which was inadvertently omitted
from my letter dated June 6, 2005 that accompanied Amendment No. 3 to the
Registration Statement on Form S-1 filed by Eagle Bulk Shipping Inc. (the
“Company”).   Exhibit 1 relates to the
Company’s response to comment 5 contained in the Staff’s comment letter dated
May 31, 2005.

Please feel free to contact me at (212) 574-1223 or
Robert Lustrin at (212) 574-1420 with any questions or comments.

  Very
  truly yours,

  /s/
  Gary J. Wolfe

  Gary
  J. Wolfe

Enclosure

cc:           Jeff
Jaramillo

Exhibit
1

Eagle
Bulk Shipping Inc.

Comparison
of Charter Rates vs. Market Rates

  Summary

  Shikra

  Kite

  Griffon

  Peregrine

  Sparrow

  Net Quarter

  2005

  Second Quarter

  63,000

  52,000

  90,000

  —

  —

  205,000

  Third Quarter

  92,000

  92,000

  276,000

  (184,000

  )

  (152,500

  )

  123,500

  Fourth Quarter

  92,000

  92,000

  276,000

  (184,000

  )

  (230,000

  )

  46,000

  2006

  First Quarter

  90,000

  59,000

  93,000

  (180,000

  )

  (225,000

  )

  (163,000

  )

  Second Quarter

  91,000

  —

  —

  (182,000

  )

  (227,500

  )

  (318,500

  )

  Third Quarter

  —

  —

  —

  (184,000

  )

  (230,000

  )

  (414,000

  )

  Fourth Quarter

  —

  —

  —

  —

  (77,500

  )

  (77,500

  )

  Grand Total

  428,000

  295,000

  735,000

  (914,000

  )

  (1,142,500

  )

  (598,500

  )

Vessel
by Vessel Detail:

  Vessel

  Shikra

  Delivery

  4/29/2005

  Expiry

  7/1/2006

  Total Length

  14
  months

  Charter

  Market

  Excess

  #days

  Excess

  Rate

  Rate

  (Under)

  in
  month

  (Under)

  2005

  April

  22,000

  21,000

  1,000

  2

  May

  22,000

  21,000

  1,000

  31

  June

  22,000

  21,000

  1,000

  30

  Total Quarter

  63

  63,000

  July

  22,000

  21,000

  1,000

  31

  August

  22,000

  21,000

  1,000

  31

  September

  22,000

  21,000

  1,000

  30

  Total Quarter

  92

  92,000

  October

  22,000

  21,000

  1,000

  31

  November

  22,000

  21,000

  1,000

  30

  December

  22,000

  21,000

  1,000

  31

  Total Quarter

  92

  92,000

  2006

  January

  22,000

  21,000

  1,000

  31

  February

  22,000

  21,000

  1,000

  28

  March

  22,000

  21,000

  1,000

  31

  Total Quarter

  90

  90,000

  April

  22,000

  21,000

  1,000

  30

  May

  22,000

  21,000

  1,000

  31

  June

  22,000

  21,000

  1,000

  30

  Total Quarter

  91

  91,000

  July

  August

  September

  Total Quarter

  October

  November

  December

  Total Quarter

  Grand Total

  428

  428,000

  Vessel

  Kite

  Delivery

  5/9/2005

  Expiry

  3/1/2006

  Total Length

  9.7
  months

  Charter

  Market

  Excess

  #days

  Excess

  Rate

  Rate

  (Under)

  in
  quarter

  (Under)

  2005

  April

  25,000

  24,000

  1,000

  May

  25,000

  24,000

  1,000

  22

  June

  25,000

  24,000

  1,000

  30

  Total Quarter

  52

  52,000

  July

  25,000

  24,000

  1,000

  31

  August

  25,000

  24,000

  1,000

  31

  September

  25,000

  24,000

  1,000

  30

  Total Quarter

  92

  92,000

  October

  25,000

  24,000

  1,000

  31

  November

  25,000

  24,000

  1,000

  30

  December

  25,000

  24,000

  1,000

  31

  Total Quarter

  92

  92,000

  2006

  January

  25,000

  24,000

  1,000

  31

  February

  25,000

  24,000

  1,000

  28

  March

  25,000

  24,000

  1,000

  —

  Total Quarter

  59

  59,000

  April

  May

  June

  Total Quarter

  July

  August

  September

  Total Quarter

  October

  November

  December

  Total Quarter

  Grand Total

  295

  295,000

2

  Vessel

  Griffon

  Delivery

  6/1/2005

  Expiry

  2/1/2006

  Total Length

  8
  months

  Charter

  Market

  Excess

  #days

  Excess

  Rate

  Rate

  (Under)

  in
  quarter

  (Under)

  2005

  April

  May

  June

  28,000

  25,000

  3,000

  30

  Total Quarter

  30

  90,000

  July

  28,000

  25,000

  3,000

  31

  August

  28,000

  25,000

  3,000

  31

  September

  28,000

  25,000

  3,000

  30

  Total Quarter

  92

  276,000

  October

  28,000

  25,000

  3,000

  31

  November

  28,000

  25,000

  3,000

  30

  December

  28,000

  25,000

  3,000

  31

  Total Quarter

  92

  276,000

  2006

  January

  28,000

  25,000

  3,000

  31

  February

  28,000

  25,000

  3,000

  —

  March

  —

  —

  —

  —

  Total Quarter

  31

  93,000

  April

  May

  June

  Total Quarter

  July

  August

  September

  Total Quarter

  October

  November

  December

  Total Quarter

  245

  735,000

3

  Vessel

  Peregrine

  Est. Delivery

  6/30/2005

  Expiry

  10/1/2006

  Total Length

  15
  months

  Charter

  Market

  Excess

  #days

  Excess

  Rate

  Rate

  (Under)

  in
  quarter

  (Under)

  2005

  April

  May

  June

  Total Quarter

  0

  July

  24,000

  26,000

  (2,000

  )

  31

  August

  24,000

  26,000

  (2,000

  )

  31

  September

  24,000

  26,000

  (2,000

  )

  30

  Total Quarter

  92

  (184,000

  )

  October

  24,000

  26,000

  (2,000

  )

  31

  November

  24,000

  26,000

  (2,000

  )

  30

  December

  24,000

  26,000

  (2,000

  )

  31

  Total Quarter

  92

  (184,000

  )

  2006

  January

  24,000

  26,000

  (2,000

  )

  31

  February

  24,000

  26,000

  (2,000

  )

  28

  March

  24,000

  26,000

  (2,000

  )

  31

  Total Quarter

  90

  (180,000

  )

  April

  24,000

  26,000

  (2,000

  )

  30

  May

  24,000

  26,000

  (2,000

  )

  31

  June

  24,000

  26,000

  (2,000

  )

  30

  Total Quarter

  91

  (182,000

  )

  July

  24,000

  26,000

  (2,000

  )

  31

  August

  24,000

  26,000

  (2,000

  )

  30

  September

  24,000

  26,000

  (2,000

  )

  31

  Total Quarter

  92

  (184,000

  )

  October

  November

  December

  Total Quarter

  457

  (914,000

  )

4

  Vessel

  Sparrow

  Est. Delivery

  7/31/2005

  Expiry

  11/1/2006

  Total Length

  15
  months

  Charter

  Market

  Excess

  #days

  Excess

  Rate

  Rate

  (Under)

  in
  quarter

  (Under)

  2005

  April

  May

  June

  Total Quarter

  July

  August

  22,500

  25,000

  (2,500

  )

  31

  September

  22,500

  25,000

  (2,500

  )

  30

  Total Quarter

  61

  (152,500

  )

  October

  22,500

  25,000

  (2,500

  )

  31

  November

  22,500

  25,000

  (2,500

  )

  30

  December

  22,500

  25,000

  (2,500

  )

  31

  Total Quarter

  92

  (230,000

  )

  2006

  January

  22,500

  25,000

  (2,500

  )

  31

  February

  22,500

  25,000

  (2,500

  )

  28

  March

  22,500

  25,000

  (2,500

  )

  31

  Total Quarter

  90

  (225,000

  )

  April

  22,500

  25,000

  (2,500

  )

  30

  May

  22,500

  25,000

  (2,500

  )

  31

  June

  22,500

  25,000

  (2,500

  )

  30

  Total Quarter

  91

  (227,500

  )

  July

  22,500

  25,000

  (2,500

  )

  31

  August

  22,500

  25,000

  (2,500

  )

  30

  September

  22,500

  25,000

  (2,500

  )

  31

  Total Quarter

  92

  (230,000

  )

  October

  22,500

  25,000

  (2,500

  )

  31

  November

  —

  —

  —

  December

  —

  —

  —

  Total Quarter

  31

  (77,500

  )

  457

  (1,142,500

  )

5