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August 12, 2020
Petros Panagiotidis
Chairman, Chief Executive Officer and Chief Financial Officer
Castor Maritime Inc.
223 Christodoulou Chatzipavlou Street
Hawaii Royal Gardens
3036 Limassol, Cyprus
Re:Castor Maritime Inc.
Registration Statement on Form F-3
Filed July 31, 2020
File No. 333-240262
Dear Mr. Panagiotidis:
            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.
Registration Statement on Form F-3
General
1.We note that you relied on General Instruction I.B.5 to Form F-3 to conduct your
registered direct offering in July 2020, and note that in a concurrent private placement you
sold to the investors the warrants that you are registering for resale in this F-3.  Because
the aggregate number of shares sold by you to the selling shareholders in the registered
direct offering and number of common shares underlying the warrants sold by you in the
private placement exceeds the limitation in General Instruction I.B.5, it does not appear
that you are eligible to rely on General Instruction I.B.3 to Form F-3 to register the resale
of these securities.  For guidance, please consider Securities Act Forms Compliance and
Disclosure Interpretation 116.25.  Accordingly, with respect to the resale of these warrants

 FirstName LastNamePetros Panagiotidis
 Comapany NameCastor Maritime Inc.
 August 12, 2020 Page 2
 FirstName LastName
Petros Panagiotidis
Castor Maritime Inc.
August 12, 2020
Page 2
and common shares, please amend your registration statement to a form on which you are
eligible to conduct a primary offering of securities with a market value of the securities
that you have attempted to register on Form F-3.  Alternatively, provide us with an
analysis supporting your eligibility to use Form F-3 to register the resale of these warrants
and common shares.
            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 Laura Nicholson, Special Counsel, at 202-551-3584 or Loan Lauren
Nguyen, Legal Branch Chief, at 202-551-3642 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Edward S. Horton