SEC Comment Letter for International Seaways, Inc. (INSW) (CIK 0001679049) (INSW) — May 8, 2018
International Seaways, Inc. (INSW) (CIK 0001679049)
Date: May 8, 2018 · CIK: 0001679049 · Accession: 0000000000-18-014235
AI Filing Summary & Sentiment
File numbers found in text: 333-224313
Show Raw Text
May 7, 2018
Lois Zabrocky
Chief Executive Officer
International Seaways, Inc.
600 Third Avenue, 39th Floor
New York, NY 10016
Re:International Seaways, Inc.
Registration Statement on Form S-3
Filed April 17, 2018
File No. 333-224313
Dear Mr. Zabrocky:
We have limited our review of your registration statement to those issues we have
addressed in our 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 information. 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
provide in response to these comments, we may have additional comments.
Form S-3 filed April 17, 2018
Cover Page
1.Please refer to footnote 1. We note your disclosure that "[s]ecurities registered hereunder
may be sold separately, together or as units with other securities registered hereunder."
Please revise the registration statement to register the offering of units, revise the
prospectus throughout, as applicable, and file the required opinions of counsel with
respect to the units. Alternatively, please confirm that you will not be offering any units
and revise this footnote accordingly.
FirstName LastNameLois Zabrocky
Comapany NameInternational Seaways, Inc.
May 7, 2018 Page 2
FirstName LastName
Lois Zabrocky
International Seaways, Inc.
May 7, 2018
Page 2
Description of Preferred Stock, page 15
2.We note your disclosure in the first paragraph that no preferred stock is outstanding. We
also note your reference to identifying selling security holders in a prospectus
supplement. Please delete such reference as you do not appear to comply with the
requirements of Rule 430B(b)(2) of the Securities Act of 1933 or, alternatively, please
advise.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Donald E. Field at (202) 551-3680 or Laura Nicholson at (202) 551-
3584 with any questions.
Division of Corporation Finance
Office of Transportation and Leisure