SecProbe.io

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Mail Stop 03-05
							May 31, 2005

Gary J. Wolfe, Esq.
Seward & Kissel LLP
One Battery Park Plaza
New York, New York 10004

Re:	Aries Maritime Transport Limited
	Amendment No. 3 to the Registration Statement on
      Form F-1
	Filed on May 16, 2005
      File No. 333-124952

Dear Mr. Wolfe,

      We have reviewed your 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. Please note that all previously filed amendments and
correspondence must be filed on EDGAR.  We request that you file
the
materials on Edgar prior to submitting your next amendment.  See
Release No. 33-8099 which is currently available on our website at
www.sec.gov./rules/final/33-8099.htm.

2. We note the inclusion on page F-2 of an audit report that will
be
furnished upon the completion of the stock split on March 21,
2005.
Please provide a final updated and signed audit report in an
amendment to your filing.

Legal Matters, page 97
3. We note your response to our prior comment 7 but it appears
that
Appleby Spurling Hunter is passing upon the validity of the shares
and it should reflect that here.  Please revise or advise.

Exhibits
Exhibit 5.1
4. We partly reissue comment 10.  Please remove assumption (g)
from
the opinion of counsel, or advise us why you think it is
appropriate.
5. We note your response to comment 11 and reissue the comment.
It
is not clear to us that subsection (2) under the "opinion"
indicates
that all necessary action required relates to the due
authorization.
Please revise to make this clear.  To help with clarity, please
delete the opening part of subsection (3) that says "when the
issue
of the shares have been duly approved," as the opinion should be
clear that the shares are duly authorized.
6. We note your response to comment 12.  Please revise the opinion
to
clarify that (4)(i) is the opinion of counsel - that permission
has
been obtained from the Bermuda Monetary Authority for the issue
and
transfer of the common shares and that the registration statement
.
7. Also, we note your response to prior comment 12 and that you
indicate in paragraph 4(ii) under "opinion," that the Registration
Statement must be filed with the Registrar of Companies "prior to
or
as soon as reasonably practicable after any shares are offered to
the
public."  In light of this, please further provide an explanation
as
to why you can not opine on the matter set forth in paragraph
(4)(ii)
and / or why you believe this is an appropriate assumption.
8. We note your statement that the opinion speaks as of its date.
As
the opinion must speak to the date of effectiveness, either delete
this statement or file an updated opinion at effectiveness.
Similarly revise exhibit 8.2.

Exhibit 8.2
9. We note your response to our prior comment 16.  Please revise
to
state that the discussion under "Bermuda Tax Considerations" is
counsel`s opinion.

Closing

      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.

      You may contact Tracie Northan at (202) 551-3311 or Michael
Fay
at (202) 551-3812, if you have questions regarding comments on the
financial statements and related matters.  Please contact Messeret
Nega at (202) 551-3316 or me at (202) 551-3210 with any other
questions.

Sincerely,

Susan Block
Attorney-Advisor

cc:	Via Facsimile
	Gary J. Wolfe, Esq.
	Seward & Kissel LLP
      (212) 480-8421

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Gary J. Wolfe, Esq.
Aries Maritime Transport Limited
May 31, 2005
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