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SEC Company Response from International Seaways, Inc. (INSW) (CIK 0001679049) (INSW) — Aug 29, 2018

International Seaways, Inc. (INSW) (CIK 0001679049)
Date: Aug. 29, 2018 · CIK: 0001679049 · Accession: 0001144204-18-046846

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File numbers found in text: 333-226946

Date
August 29, 2018
Author
James D. Small III
Form
CORRESP
Company
International Seaways, Inc. (INSW) (CIK 0001679049)

Letter

VIA EDGAR CORRESPONDENCE Division of Corporate Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: International Seaways, Inc. Registration Statement on Form S-3 (File No. 333-226946)

Dear Ms. Bednarowski:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, International Seaways, Inc. (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form S-3, as amended, be accelerated so that it will be declared effective by 4:00 pm, Eastern Time, on Thursday, August 30, 2018, or as soon thereafter as reasonably practicable (the “Effective Date”).

The Company hereby acknowledges its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the above-referenced Registration Statement. In addition, the Company hereby acknowledges that:

· should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement 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 Registration Statement 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.

Ms. Laura Nicholson

August 29, 2018

Page 2

Please contact Jeffrey D. Karpf of Cleary Gottlieb Steen & Hamilton LLP at (212) 225-2864, counsel to the Company, if you have any questions or concerns regarding this matter.

Very truly yours,
International Seaways, Inc.

Show Raw Text
CORRESP
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filename1.htm

        600 Third Avenue

        39th Floor

        New York, NY 10016

        USA

        Tel:  +1 212-251-1199

        Fax:  +1 212-251-1180

        E-mail: jsmall@intlseas.com

        James D. Small III

        Chief Administrative Officer,

        Senior Vice President,

Secretary & General
Counsel

August 29, 2018

VIA EDGAR CORRESPONDENCE

Ms. Sonia Bednarowski

Division of Corporate Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    International Seaways, Inc.

    Registration Statement on Form S-3 (File No. 333-226946)

Dear Ms. Bednarowski:

Pursuant to Rule 461 under the Securities
Act of 1933, as amended, International Seaways, Inc. (the “Company”) hereby requests that the effectiveness
of the above-referenced Registration Statement on Form S-3, as amended, be accelerated so that it will be declared effective by
4:00 pm, Eastern Time, on Thursday, August 30, 2018, or as soon thereafter as reasonably practicable (the “Effective Date”).

The Company hereby acknowledges its responsibilities
under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed
public offering of the securities specified in the above-referenced Registration Statement. In addition, the Company hereby acknowledges
that:

 · should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated
authority, declare the Registration Statement 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 Registration Statement
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.

Ms. Laura Nicholson

August 29, 2018

Page 2

Please contact Jeffrey D. Karpf of Cleary
Gottlieb Steen & Hamilton LLP at (212) 225-2864, counsel to the Company, if you have any questions or concerns regarding this
matter.

    Very truly yours,

    International Seaways, Inc.

    By:
    /s/ James D. Small III

    Name:
    James D. Small III

    Title:
    Chief Administrative Officer, Senior Vice President, Secretary and General
    Counsel

    cc:
    Lois K. Zabrocky

    International Seaways, Inc.

    Jeffrey D. Karpf, Esq.

    Marc Rotter, Esq.

    Cleary Gottlieb Steen & Hamilton LLP