SecProbe.io

Mail Stop 3030
August 11, 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 No. 2 to Registration Statement on Form S -1
  Response Dated August 8, 2016
  File No. 333 -212377

Dear Mr. Tsirigakis :

We have reviewed  your August 8, 2016 response to our comment letter 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.    Unless we note
otherwise, our references to prior comments are to comments in our August 5, 2016 letter .

1. We note your statement that the sponsors will waive their right to be repaid.  Please file
the waiver as an exhibit.  If you do not have an executed waiver, please revise to disclose
that the sponsors have not waived, and may not, their right to be repaid in the event that
the company does not consummate a business combination.   In addition, in the event that
you are required to repay the loans, disclose the source of funds that will be used for
repayment .
.
2. We note your response to prior comment 3. Please revise to prominently disclose that the
terms of the promissory note to be issu ed in connection with the extension loans ha ve not
been negotiated. In addition, please provide appropriate risk factor disclosure to address
the risk that the extension loans may not be made on the terms described in the
prospectus.

Prokopios (Akis) Tsirigakis
Stellar Acquisition III Inc.
August 11, 2016
Page 2

 3. We note your response to prior comment 5. We also note that Section 9.2(d) appears to
govern the company’s obligation to fully redeem shares if a business combination is not
consummated.  According to Section 9.7, any amendment to the “substance or timing” of
that obligation wi ll trigger shareholder redemption rights that are “subject to the
Redemption L imitation. ”  That is, i n the event of an amendment, the limitation contained
in Section 9.7 appears to mean that the shares may not be fully redeemed . Please revise
your pr ospect us disclosure to clarify how the redemption right would apply or,
alternatively, provide further analysis as to why you believe that revisions are not
necessary.

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.