SecProbe.io

December 21, 2011
 Via E-mail

Mr. Gregory G. Zikos
Chief Financial Officer
Costamare Inc. 60 Zephyrou Street & Syngrou Avenue 17564, Athens, Greece
Re: Costamare Inc.
 Form 20-F for the year ended December 31, 2010
Filed March 22, 2011 File No.
001-34934

Dear Mr. Zikos:
 We have reviewed your filing and have the following 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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 20-F for the fiscal year ended December 31, 2010

 Protection and Indemnity Insuranc e – Pollution coverage, page 36

 1. You indicate that, as a member of a P&I association, which is a member of the
International Group, you will be subject to call s payable to the P&I association based on
the International Group’s claim records,  as  well as the claim records of all other
members of the association.  In this regard, please disclose whether there is a cap on your
liability exposure for calls payable to the P&I association and quantify such cap.  In
addition, please disclose the amount of any ma terial call payables, or refunds received,
for each reporting period.  Also, please tell us the financial statement line item[s] that
include[s] call payables t o, or refunds received fro m, the P&I association.

Gregory G. Zikos
Costamare Inc.
December 21, 2011 Page 2

 Item 5.  Operating and Financial Review and Propects, page 44

 Critical Accounting Policies, page 67

 Vessel Impairment, page 68

 2. You indicate that an internal analysis, whic h used a discounted cash flow model utilizing
inputs and assumptions based on market obs ervations as of December 31, 2010, suggests
that five of your 43 vessels may have current market values below their carrying values.
In this regard, please consider expanding your  disclosure to include a table summarizing
your owned vessels that detail s, by vessel, the date of acquisition, purchase price and
carrying value at the balance sheet date.  Plea se identify within this table those vessels
whose estimated market values are less than their carrying values.  In this regard, for
those vessels whose market value is below their carrying value, please add disclosure
below the table of the aggregate market valu e and aggregate book value of such vessels.
This additional disclosure will provide inve stors with an indication of the estimated
magnitude of the potential aggregate impairment  charge related to these vessels, as of
December 31, 2010, if you decided to sell all of  such vessels.  Also, the disclosure
accompanying the table should discuss the re lated accounting treatment of your vessels,
and describe the circumstances under whic h you would record an impairment loss for
such vessels.  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Gregory G. Zikos
Costamare Inc.
December 21, 2011 Page 3

 You may contact Beverly A. Singleton at  (202) 551-3328 or Juan Migone, Review
Accountant, at (202) 551-3312 if you have que stions regarding comments on the financial
statements and related matters.  Please contac t me at (202) 551-3211 with any other questions.

Sincerely,
   /s/ David R. Humphrey
David R. Humphrey Accounting Branch Chief