SEC Comment Letter 0000000000-24-002332 to GENCO SHIPPING & TRADING LTD (GNK) (CIK 0001326200) (GNK)
GENCO SHIPPING & TRADING LTD (GNK) (CIK 0001326200)
Date: March 1, 2024 · CIK: 0001326200 · Accession: 0000000000-24-002332
AI Filing Summary & Sentiment
File numbers found in text: 001-33393
Letter
United States securities and exchange commission logo March 1, 2024 Kleanthis Costa Spathias Director, Sphinx Investment Corp. GK Investor LLC c/o Levante Services Limited Leoforos Evagorou 31, 2nd Floor, Office 21 1066 Nicosia, Cyprus Re:GK Investor LLC Genco Shipping & Trading Limited DFAN14A Filed January 10, 2024 Filed By GK Investor LLC et al. File No. 001-33393 Dear Kleanthis Costa Spathias: We have reviewed your filing and have the following comment. Please respond to this comment by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. DFAN14A Filed January 10, 2024 Certain Information Concerning the Participants 1.In written soliciting materials used before a proxy statement is furnished, Rule 14a- 12(a)(1)(i) requires the soliciting party to include a description of each participant’s direct and indirect interests in the solicitation, or a legend advising where that information can be found. Such interests are not limited to the participant’s share ownership in the registrant. See the last sentence of CDI 132.03 under Proxy Rules and Schedules 14A/14C Compliance and Disclosure Interpretations (November 17, 2023). Consider whether Mr. Economou’s ownership interest in a rival shipping company, DryShips Inc., and Sphinx Investment Corp.'s pending offer to acquire all issued and outstanding common shares of another shipping company, Performance Shipping Inc., constitute interests in this solicitation. Please disclose in future filings, or advise.
FirstName LastNameKleanthis Costa Spathias Comapany NameGK Investor LLC March 1, 2024 Page 2 FirstName LastName Kleanthis Costa Spathias GK Investor LLC March 1, 2024 Page 2 We remind you that the filing persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please direct any questions to Shane Callaghan at 202-551-6977 or Christina Chalk at 202-551-3263. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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United States securities and exchange commission logo
March 1, 2024
Kleanthis Costa Spathias
Director, Sphinx Investment Corp.
GK Investor LLC
c/o Levante Services Limited
Leoforos Evagorou 31, 2nd Floor, Office 21
1066 Nicosia, Cyprus
Re:GK Investor LLC
Genco Shipping & Trading Limited
DFAN14A Filed January 10, 2024
Filed By GK Investor LLC et al.
File No. 001-33393
Dear Kleanthis Costa Spathias:
We have reviewed your filing and have the following comment.
Please respond to this comment by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comment applies to your facts
and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
DFAN14A Filed January 10, 2024
Certain Information Concerning the Participants
1.In written soliciting materials used before a proxy statement is furnished, Rule 14a-
12(a)(1)(i) requires the soliciting party to include a description of each participant’s direct
and indirect interests in the solicitation, or a legend advising where that information can
be found. Such interests are not limited to the participant’s share ownership in the
registrant. See the last sentence of CDI 132.03 under Proxy Rules and Schedules 14A/14C
Compliance and Disclosure Interpretations (November 17, 2023). Consider whether Mr.
Economou’s ownership interest in a rival shipping company, DryShips Inc., and Sphinx
Investment Corp.'s pending offer to acquire all issued and outstanding common shares of
another shipping company, Performance Shipping Inc., constitute interests in this
solicitation. Please disclose in future filings, or advise.
FirstName LastNameKleanthis Costa Spathias
Comapany NameGK Investor LLC
March 1, 2024 Page 2
FirstName LastName
Kleanthis Costa Spathias
GK Investor LLC
March 1, 2024
Page 2
We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please direct any questions to Shane Callaghan at 202-551-6977 or Christina Chalk at
202-551-3263.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions