SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
CORPORATION FINANCE

   May 20, 2011
  Symeon Palios Chairman and Chief Executive Officer Diana Containerships Inc. Pendelis 16 175 64 Palaio Faliro Athens, Greece
Re:  Diana Containerships Inc.
Registration Statement on Form F-1 Filed on May 9, 2011 File number 333-174053

Dear Mr. Palios:

We have limited our review of your registra tion statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter by amendi ng your registration statement and providing
the requested information.  Where you do not be lieve our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information
you provide in response to these comments,  we may have additional comments.
 Risk Factors, page 14

If our vessels call on ports located in countries that are subject to rest rictions imposed by the
U.S. or other governments, that could adversel y affect our reputation and the market for our
common stock, page 22

1. You state that your vessels may call on ports  located in countr ies identified by the
U.S. government as state sponsors of terrorism.  Please confirm to us that in future filings you will revise your risk f actor disclosure to name the countries
identified by the U.S. government as state sponsors of terrorism to which you refer.

Symeon Palios
Diana Containerships Inc. May 20, 2011 Page 2
In this regard, we note that Cuba, Iran, S udan, and Syria are identified by the U.S.
Department of State as state sponsors of terrorism, and are subject to U.S.
economic sanctions and export controls.  Your filing does not include disclosure
regarding contacts with the referenced count ries.  Describe to us the nature and
extent of any past, current, and antici pated contacts with Cuba, Iran, Sudan, and
Syria, whether through subsidiaries or othe r direct or indirect  arrangements, since
your inception.  Further, you should describe  to us any goods, fees, or services
you have provided or anticipate providing, directly or indirectly, to the referenced
countries, and any agreements, commercial  arrangements, or other contacts you
have had, or intend to have, directly or i ndirectly, with the gove rnments or entities
controlled by the governments of those countries.

2. Please discuss for us the materiality of any contacts with Cuba, Iran, Sudan, and
Syria you describe in response to th e foregoing comment, and whether those
contacts constitute a material investment  risk for your security holders.  You
should address materiality in quantitative terms, including the approximate dollar
amounts of any revenues, assets, and liab ilities associated with each of the
referenced countries since your inception.  Also, address materiality in terms of
qualitative factors that a reasonable inve stor would deem important in making an
investment decision, including the potentia l impact of corpor ate activities upon a
company’s reputation and share value.   As you may know, various state and
municipal governments, uni versities, and ot her investors have proposed or
adopted divestment or similar initiatives regarding investment in companies that
do business with U.S.-designated state s ponsors of terrorism.  Your materiality
analysis should address the potential imp act of the investor sentiment evidenced
by such actions directed toward companie s that have contacts with Cuba, Iran,
Sudan, or Syria.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that th e filing includes the information the Securities Act
of 1933 and all applicable S ecurities Act rules require.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request accelerati on of the effective
date of the pending registration statement pl ease provide a written statement from the
company acknowledging that:

• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;

Symeon Palios
Diana Containerships Inc. May 20, 2011 Page 3
• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of th e disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
 Please refer to Rules 460 and 461 regard ing requests for acceleration.  We will
consider a written request for acceleration of th e effective date of th e registration statement
as confirmation of the fact that those request ing acceleration are aware of their respective
responsibilities under the Securi ties Act of 1933 and the Securiti es Exchange Act of 1934 as
they relate to the proposed public offering of th e securities specified in  the above registration
statement.  Please allow adequate time for us to review any amendment prior to the requested
effective date of the regist ration statement.
 You may contact Tonya Bryan at (202) 551- 3601 or me at (202) 551-3469 with any
questions.
Sincerely,     Justin Dobbie Legal Branch Chief
 cc:  Gary J. Wolfe
Edward S. Horton, Esq. Seward & Kissel LLP (212) 480-8421 (facsimile)