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April 11, 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
PREC14A Filed April 8, 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 comments.
            Please respond to these comments by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comments apply to your facts
and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
All defined terms used herein have the same meaning as in your proxy statement.
PREC14A Filed April 8, 2024
General Comments, page 1
1.Under the heading 'Incorporation by Reference,' we note that you direct shareholders to
the Company's definitive proxy statement (when filed) for "[i]nformation concerning the
date by which shareholder proposals intended to be presented at the next annual meeting
of shareholders must be received by the Company for inclusion in the Company Proxy
Statement." Please revise to provide the disclosure required by Rule 14a-5(e) with respect
to director nominations for next year's annual meeting.
2.On the preliminary proxy card, you indicate that the proxy card will be voted based on the
GK Parties’ recommendations if the proxy card does not specify how the proxy should be
voted. Please revise to clarify whether you are describing an entirely unmarked, but signed
proxy card, or one that is signed and marked as to other matters but not marked as to the

 FirstName LastNameKleanthis Costa Spathias
 Comapany NameGK Investor LLC
 April 11, 2024 Page 2
 FirstName LastName
Kleanthis Costa Spathias
GK Investor LLC
April 11, 2024
Page 2
particular proposal addressed in your disclosure.
Questions and Answers Relating to this Proxy Solicitation, page 13
3.On page 17 of the Proxy Statement, you indicate that record holders of the Common Stock
can vote their shares by completing the BLUE proxy card or “by instructing us by
telephone or via the Internet as to how you would like your shares voted (instructions are
on your BLUE universal proxy card [sic].” The preliminary proxy card does not appear to
provide record holders of the Common Stock with instructions on how to vote by
telephone or via the Internet. Please revise or advise.
Proposal No. 1 - Election of Directors, page 19
4.On page 20 of the Proxy Statement, you state that the Company’s non-chairman directors
were each granted RSUs “with respect to 7,288 shares of Common Shares, representing a
grant having a dollar value of $100,000 based on such closing price” according to the
Company Proxy Statement. Please revise to state the grant date of these RSUs.
            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