SecProbe.io

July 8, 201 9
Via E-mail
Konstantinos Konstantakopoulos
Chief Executive  Officer
Costamare Inc .
7 rue de Gabian
MC 98000 Monaco

 Re: Costamare Inc .
  Form 20-F for the Fiscal Year Ended December 31, 201 8
  Filed March 7 , 2019
  File No. 1 -34934

Dear Mr. Konstantakopoulos :

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our comments , we ask you to provide us with information so we may better
understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e 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.

Risk Factors, page 3
Our vessels may call on ports located in countries that are subject to restrictions…, page 29

1. You do not provide information  about port calls to Sudan.  Publicly available information
about some of the companies you identify as charterers indicates that those companies have
offices in, and shipping routes that include, Sudan.  Sudan is  designated by the U.S.
Department of State  as a state sponsor of terrorism , and it is subject to U.S. export controls.
Please describe to us the nature and extent of any past, current, and anticipated contacts with
Sudan during the past three fiscal years and the subsequent interim period, includ ing contacts
with Sudan’s’ government, whether through subsidiaries, charterers, affiliates, or other direct
or indirect arrangements.  Discuss for us the materiality of any such contacts, in quantitative
terms and in terms of qualitative factors that a re asonable investor would deem important in
making an investment decision.  Te ll us the approximate dollar amounts of any revenues,
assets and liabilities associated with Sudan for the last three fiscal years and the subsequent
interim period .

Konstantinos Konstantakopoulos
Costamare Inc.
 July 8, 2019
 Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny 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 provide  a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

You may contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

Sincerely,

 /s/ Cecilia Bl ye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  C. Scott Bennett, Esq.
  Cravath , Swaine & Moore  LLP

  Anne Parker
  Assistant Director