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SEC Company Response from GENCO SHIPPING & TRADING LTD (GNK) (CIK 0001326200) (GNK) — Jul 21, 2005

GENCO SHIPPING & TRADING LTD (GNK) (CIK 0001326200)
Date: July 21, 2005 · CIK: 0001326200 · Accession: 0001047469-05-019815

AI Filing Summary & Sentiment

File numbers found in text: 333-124718

Date
July 21, 2005
Author
Managing Director
Form
CORRESP
Company
GENCO SHIPPING & TRADING LTD (GNK) (CIK 0001326200)

Letter

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[JEFFERIES & COMPANY, INC. LETTERHEAD]

July 21,

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-0305

Attention: Jennifer G. Williams

Re:Genco Shipping and Trading Limited

Amendment No. 5 to Registration Statement on Form S-1

File No. 333-124718

Ladies and Gentlemen:

Genco Shipping & Trading Limited (the "Company"), has filed today via EDGAR Amendment No. 5 to its Registration Statement on Form S-1 ("Amendment No. 5") under the Securities Act of 1933, as amended, in connection with a proposed initial public offering of common stock by the Company and its shareholder (the "Offering").

As requested, we hereby confirm that prospective underwriters, dealers, institutional investors and other potential investors in the Company have been informed of the following, all of which are disclosed in the preliminary prospectus dated July 21, 2005 that forms a part of Amendment No. 5:

•the increase in the number of shares of common stock being offered by the Company to 11,300,000 shares;

•Fleet Acquisition LLC, the Company's shareholder, will not be offering any firm shares of Company common stock in the Offering, but will be offering up to 1,695,000 shares of common stock pursuant to the underwriters' over-allotment option;

•the decrease in the estimated offering price range to $22.00—$23.00 per share; and

•the other changes from the disclosures contained in the preliminary prospectus dated July 6, 2005.

Please feel free to contact Ted Paris of Baker Botts L.L.P., our outside counsel, at (713) 229-1838, with any questions.

Very truly yours,
JEFFERIES & COMPANY, INC.

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CORRESP
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 -- Click here to rapidly navigate through this document

[JEFFERIES & COMPANY, INC. LETTERHEAD]

July 21,
2005

Securities
and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-0305

Attention: Jennifer G. Williams

Re:Genco Shipping and Trading Limited

Amendment No. 5 to Registration Statement on Form S-1

File No. 333-124718

Ladies and Gentlemen:

        Genco
Shipping & Trading Limited (the "Company"), has filed today via EDGAR Amendment No. 5 to its Registration Statement on Form S-1 ("Amendment
No. 5") under the Securities Act of 1933, as amended, in connection with a proposed initial public offering of common stock by the Company and its shareholder (the "Offering").

        As
requested, we hereby confirm that prospective underwriters, dealers, institutional investors and other potential investors in the Company have been informed of the following, all of
which are disclosed in the preliminary prospectus dated July 21, 2005 that forms a part of Amendment No. 5:

•the
increase in the number of shares of common stock being offered by the Company to 11,300,000 shares;

•Fleet
Acquisition LLC, the Company's shareholder, will not be offering any firm shares of Company common stock in the Offering, but will be offering up to 1,695,000 shares
of common stock pursuant to the underwriters' over-allotment option;

•the
decrease in the estimated offering price range to $22.00—$23.00 per share; and

•the
other changes from the disclosures contained in the preliminary prospectus dated July 6, 2005.

        Please
feel free to contact Ted Paris of Baker Botts L.L.P., our outside counsel, at (713) 229-1838, with any questions.

Very truly yours,

JEFFERIES & COMPANY, INC.

MORGAN STANLEY & CO. INCORPORATED

As Representatives of the several

Underwriters

By:

JEFFERIES & COMPANY, INC.

By:

/s/  MICHAEL A. BAUER       Michael A. Bauer

Managing Director

cc:Rolaine
S. Bancroft

Securities and Exchange Commission

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[JEFFERIES & COMPANY, INC. LETTERHEAD]