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corresp

                    May 23, 2011

Securities And Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Justin Dobbie

    Legal Branch Chief

    Re:

    Diana Containerships Inc.

    Registration Statement on Form F-1

    Filed on May 9, 2011

    File No. 333-174053

Dear Mr. Dobbie:

     We refer to the registration statement on Form F-1 (the “Registration Statement”) of Diana
Containerships Inc. (the “Company”) that was filed with the U.S. Securities and Exchange Commission
(the “Commission”) on May 9, 2011. By letter dated May 20, 2011 (the “Comment Letter”) the Staff
of the Commission (the “Staff”) provided the Company with its comments regarding the Registration
Statement and the prospectus included therein. On behalf of the Company, we have filed via EDGAR
the first revised registration statement on Form F-1/A (the “First Revised Registration
Statement”).

     We respond to your numbered comments in the Comment Letter as follows (page references in our
responses are to the pages in the prospectus contained in the First Revised Registration
Statement):

Justin Dobbie

May 23, 2011

Page 2

Risk Factors, page 14

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

    1.

    You state that your vessels may call on ports located in countries identified
by the U.S. government as state sponsors of terrorism. Please confirm to us that in
future filings you will revise your risk factor disclosure to name the countries
identified by the U.S. government as state sponsors of terrorism to which you refer.
In this regard, we note that Cuba, Iran, Sudan, 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 countries. Describe to us the nature and extent of any
past, current, and anticipated contacts with Cuba, Iran, Sudan, and Syria, whether
through subsidiaries or other 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 indirectly, with the governments or entities controlled by the governments
of those countries.

         The Company acknowledges the Staff’s comment number 1, and has amended the risk
factor on page 22 of the First Revised Registration Statement to include the names
of the countries identified by the U.S. government as state sponsors of terrorism,
including Cuba, Iran, Sudan, and Syria.

         The Company advises the Staff that since the Company’s inception in January
2010, none of its vessels have called on ports in Cuba, Iran, Sudan, Syria or any
other country identified by the U.S. government as a state sponsor of terrorism,
whether through subsidiaries, affiliates, or other direct or indirect arrangements.
The Company further advises the Staff that it intends to take delivery during June,
2011, of three vessels that it has agreed to acquire from A.P. Møller-Maersk A/S, or
Maersk. The Company advises the Staff that following the delivery of these vessels
to the Company, the Company intends to employ each vessel on a time charter back to
Maersk. Under the terms of these time charters, and consistent with shipping
industry practice, the charterer of each vessel will direct the vessel’s route and
loading and discharge ports and the cargoes carried, although the charter agreements
entered into with Maersk for these vessels contain express prohibitions on the
vessels calling on any ports located in Cuba or in countries that are sanctioned by
the United Nations.

         While the respective charterers of the Company’s vessels will have the ability
to direct the vessels’ routes and cargoes, the Company has no reason to believe that
its current and anticipated charterers, which consist of two large,

Justin Dobbie

May 23, 2011

Page 3

    well-known international liner companies, will intentionally engage in the
transportation of U.S. origin goods with the Company’s vessels to Cuba, Iran, Sudan
or Syria. Therefore, the Company advises the Staff that it has not had, and does
not intend to have, directly or indirectly, any agreements, commercial arrangements
or other contacts with the governments or entities controlled by the governments of,
Cuba, Iran, Sudan, or Syria, and does not intend to provide any goods or services,
whether directly or indirectly, to such countries.

    2.

    Please discuss for us the materiality of any contacts with Cuba, Iran, Sudan,
and Syria you describe in response to the 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 liabilities associated with each of the referenced countries
since your inception. Also, address materiality in terms of qualitative factors that a
reasonable investor would deem important in making an investment decision, including
the potential impact of corporate activities upon a company’s reputation and share
value. As you may know, various state and municipal governments, universities, and
other investors have proposed or adopted divestment or similar initiatives regarding
investment in companies that do business with U.S.-designated state sponsors of
terrorism. Your materiality analysis should address the potential impact of the
investor sentiment evidenced by such actions directed toward companies that have
contacts with Cuba, Iran, Sudan, or Syria.

         The Company acknowledges the Staff’s comment number 2, and advises the Staff
that, as discussed in the Company’s response to comment number 1, the Company has
not had, and does not intend to have, directly or indirectly, any agreements,
commercial arrangements, or other contacts, directly or indirectly, with the
governments of, or entities controlled by the governments of, Cuba, Iran, Sudan, or
Syria, and does not intend to provide any good or services, whether directly or
indirectly, to such countries. As noted above, although the respective charterers
of the Company’s vessels will have the ability to direct the vessels’ routes and
cargoes, the Company has no reason to believe that these charters will intentionally
engage in the transportation of U.S. origin goods with the Company’s vessels to
Cuba, Iran, Sudan or Syria.

          In addition to the change referenced above in response to the Staff’s comments, the Company
has also (i) added a risk factor on page 22 regarding a recently launched investigation of the
European Commission into certain major container liner companies; (ii) clarified its dividend
policy on pages 6, 8, 12, 25, 39 and 83; and (iii) added disclosure
regarding vessel operating expenses on page 50. If you have any questions or comments concerning this
letter, please feel free to contact the undersigned at (212) 574-1223 or Edward S. Horton, Esq. at
(212) 574-1265.

Justin Dobbie

May 23, 2011

Page 4

    Very truly yours,

SEWARD & KISSEL, LLP

    By:
                    /s/ Gary J. Wolfe

    Gary J. Wolfe, Esq.

    cc:

    Tonya Bryan

Symeon Palios

DIANA CONTAINERSHIPS INC.

Pendelis 16

175 64 Palaio Faliro

Athens, Greece

May 23, 2011

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Justin Dobbie

                                            Re:

    Diana Containerships Inc.

Registration Statement on Form F-1 (the “Registration Statement”)

Filed on May 23, 2011

File No. 333-174053

Ladies and Gentlemen:

     The undersigned registrant hereby acknowledges that:

    •

    Should the Commission or the Staff, acting pursuant to delegated authority,
declare the Registration Statement effective, it does not foreclose the
Commission from taking any action with respect to the filing;

    •

    The action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

    •

    The Company may not assert Staff comments and 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.

    Yours faithfully,

    Diana Containerships Inc.

    By:

    /s/  Symeon Palios*

    Name:

    Symeon Palios

    Title:

    Chief Executive Officer

*By Gary
J. Wolfe, attorney-in-fact.