SecProbe.io

Mail Stop 3030
August 5, 2016

Via E -mail
Prokopios (Akis) Tsirigakis
Chief Executive  Officer
Stellar Acquisition III Inc.
90 Kifissias Avenue
Maroussi 15125
Athens, Greece

Re: Stellar Acquisition III Inc.
Amendment s No. 1 and 2 to Registration Statement on Form S -1
Files July 28, 2016 and August 2, 2016
  File No. 333 -212377

Dear Mr. Tsirigakis :

We have reviewed your amended registration statement  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 by amending your registration statement and providing the
requested informati on.  If you do not believe 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 registration statement and the information you
provid e in response to these  comments , we may have additional comments.

Ability to extend time to complete business combination, page 14

1. We note your disclosure that you “would not be obligated” to repay the extension loans.
However, it is unclear whether you intend to so. If you will not repay the loans if you do
not complete an initial business combination, please revise to clearly disclose.  If you will
repay the loans if you do not complete an initial business combination, please disclose the
source of f unds  to be used to repay the loans.

Our sponsors may decide not to extend  the term, page 26

2. We note that the redemption of the trust funds will be subject to claims made by creditors
under Marshall Islands law.   Please disclose whether the extension loans would give rise
to claims by the sponsors under Marshall Islands law.

Prokopios (Akis) Tsirigakis
Stellar Acquisition III Inc.
August 5, 2016
Page 2

 Exhibits

3. We note that you have not filed the promissory note to be used in connection with the
extension loans. Please file with you r next amendment.

Exhibit 1.1

4. Please reconcil e the statement in this exhibit that  your “initial focus will be on acquiring
an operating business in the information technology consulting industry” with your
disclosure throughout your filing that you will focus  “[y]our efforts on identifying a
prospect ive target business in the international energy logistics industry.”

Exhibit 3.3

5. Please provide your analysis as to whether section 9.7 operates to pull the Redemption
Limitation into section 9.2(d). It appears that any attempt to change section 9.2(d),
whether or not successful, would trigger section 9.7 .  Please advise as to whether this
trigger would result in shareholders receiving less than 100% value.

Exhibit 10.5

6. We note that the prospectus indicates that the required loan amount for each extension
will be $460,000 if the over -allotment is exercised.  Please advise us as to where this
requirement is reflected in this agreement.

7. The exhibits to Exhibit 10.5 appear to indicate that the funds held in trust will be
transferred to an account outside of the trust before being distributed to shareholders.  If
so, please provide us your analysis of whether th at procedure increase s the risk that your
creditors or the creditors  of the business you acquire could access the funds.

You may contact Eric Atallah at (202) 551 -3663 or Jay Webb, Senior Accountant, at
(202) 551 -3603 if you have questions regarding comments on the financial statements and
related matters.  Please contact  Tom Jones at (202) 551 -3602 or Dan iel Morris, Special Counsel,
at (202) 551 -3314 with any other questions.

Sincerely,

 /s/ Daniel Morris for

 Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc:    Stuart Neuhauser, Esq.