SEC Comment Letter 0000000000-24-001546 to Icon Energy Corp (ICON)
Icon Energy Corp
Date: Feb. 8, 2024 · CIK: 0001995574 · Accession: 0000000000-24-001546
AI Filing Summary & Sentiment
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Letter
United States securities and exchange commission logo February 8, 2024 Ismini Panagiotidi Chief Executive Officer Icon Energy Corp. 17th km National Road Athens-Lamia & Foinikos Str. 14564, Nea Kifissia Athens, Greece Re:Icon Energy Corp. Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted January 26, 2024 CIK No. 0001995574 Dear Ismini Panagiotidi: We have reviewed your amended draft registration statement and have the following comments. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our January 12, 2024 letter. Amendment No.1 to Draft Registration Statement on Form F-1 Charter hire rates for dry bulk vessels are cyclical and volatile and the dry bulk market remains significantly below its historic high, page 10 1.We note your disclosure that your Initial Vessel is currently time chartered at a floating daily rate that is linked to the Baltic Panamax Index. We also note your disclosure regarding volatility of the Baltic Dry Index. If material, please also provide such volatility information regarding the Baltic Panamax Index.
FirstName LastNameIsmini Panagiotidi Comapany NameIcon Energy Corp. February 8, 2024 Page 2 FirstName LastName Ismini Panagiotidi Icon Energy Corp. February 8, 2024 Page 2 The International Dry Bulk Industry, page 58 2.We note your response to prior comment 8, and reissue such comment in part. Please revise to disclose the date of each of the charts provided on page 59 that you attribute to Braemar plc. Executive Compensation, page 76 3.Please provide updated compensation disclosure for the last full financial year. Refer to Item 6.B of Form 20-F. Index to the Consolidated Financial Statements, page F-1 4.We note your audited financial statements are more than twelve months old. Please tell us how you comply with Item 8.A.4 of Form 20-F or provide updated audited financial statements as necessary. Refer to Instruction 2 to Item 8.A.4 of Form 20-F. Please contact Steve Lo at 202-551-3394 or Craig Arakawa at 202-551-3650 if you have questions regarding comments on the financial statements and related matters. Please contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Filana Silberberg
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United States securities and exchange commission logo
February 8, 2024
Ismini Panagiotidi
Chief Executive Officer
Icon Energy Corp.
17th km National Road
Athens-Lamia & Foinikos Str.
14564, Nea Kifissia
Athens, Greece
Re:Icon Energy Corp.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted January 26, 2024
CIK No. 0001995574
Dear Ismini Panagiotidi:
We have reviewed your amended draft registration statement and have the following
comments.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
January 12, 2024 letter.
Amendment No.1 to Draft Registration Statement on Form F-1
Charter hire rates for dry bulk vessels are cyclical and volatile and the dry bulk market remains
significantly below its historic high, page 10
1.We note your disclosure that your Initial Vessel is currently time chartered at a floating
daily rate that is linked to the Baltic Panamax Index. We also note your disclosure
regarding volatility of the Baltic Dry Index. If material, please also provide such volatility
information regarding the Baltic Panamax Index.
FirstName LastNameIsmini Panagiotidi
Comapany NameIcon Energy Corp.
February 8, 2024 Page 2
FirstName LastName
Ismini Panagiotidi
Icon Energy Corp.
February 8, 2024
Page 2
The International Dry Bulk Industry, page 58
2.We note your response to prior comment 8, and reissue such comment in part. Please
revise to disclose the date of each of the charts provided on page 59 that you attribute to
Braemar plc.
Executive Compensation, page 76
3.Please provide updated compensation disclosure for the last full financial year. Refer to
Item 6.B of Form 20-F.
Index to the Consolidated Financial Statements, page F-1
4.We note your audited financial statements are more than twelve months old. Please tell us
how you comply with Item 8.A.4 of Form 20-F or provide updated audited financial
statements as necessary. Refer to Instruction 2 to Item 8.A.4 of Form 20-F.
Please contact Steve Lo at 202-551-3394 or Craig Arakawa at 202-551-3650 if you have
questions regarding comments on the financial statements and related matters. Please contact
Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Filana Silberberg