SEC Company Response from Pangaea Logistics Solutions Ltd. (PANL) (CIK 0001606909) (PANL) — Jul 20, 2015
Pangaea Logistics Solutions Ltd. (PANL) (CIK 0001606909)
Date: July 20, 2015 · CIK: 0001606909 · Accession: 0001606909-15-000016
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File numbers found in text: 333-201881
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CORRESP 1 filename1.htm Acceleration Request July 20, 2015 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-3720 Attention: John Stickel Re: Pangaea Logistics Solutions Ltd. Registration Statement of Form S-1 (File No. 333-201881) Acceleration Request Requested Date: July 22, 2015 Requested Time: 4:00 P.M. Eastern Daylight Time Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Pangaea Logistics Solutions Ltd. (the “Company”) hereby requests that the above-referenced Registration Statement on Form S-l (File No. 333-201881) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or at such later time as the Company or its counsel may orally request via telephone call to the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) (the “Registration Statement Acceleration Request”). Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Willkie Farr & Gallagher LLP, by calling Robert Rizzo at (212) 728-8162 or Hania Masud at (212) 728-8879. In connection with the acceleration request, the Company hereby acknowledges that: • should the Commission or the Staff, acting pursuant to delegated authority, declare the Registration Statement on Form S-1 effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; • 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 the disclosure in the Registration Statement; 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. [Signature page follows] * * * * Sincerely, PANGAEA LOGISTICS SOLUTIONS LTD. Anthony Laura Chief Financial Officer cc: Robert A. Rizzo Hania Masud