SecProbe.io

CORRESP
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April 15, 2024

VIA EDGAR

Ms. Christina Chalk, Senior Special
Counsel

Mr. Shane Callaghan, Special Counsel

Office of Mergers and Acquisitions

United States Securities and Exchange
Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

  Re:

  GK
  Investor LLC

Genco Shipping
 & Trading Limited

PREC14A
Filed April 8, 2024

Filed
By GK Investor LLC et al.

File
No. 001-33393

Dear Ms. Chalk and Mr. Callaghan:

This letter, which is being
submitted on behalf of GK Investor LLC (“GK”) and the other filing persons (together with GK, the “Filing
Persons”) named in the above-referenced Preliminary Proxy Statement filed with the United States Securities and Exchange Commission
(the “SEC”) on April 8, 2024 (the “Preliminary Proxy Statement”), responds to the comments
of the staff (the “Staff”) of the SEC contained in your letter dated April 11, 2024 (the “Comment Letter”)
with respect to the Preliminary Proxy Statement. Unless otherwise indicated, capitalized terms used herein have the meanings assigned
to them in the Preliminary Proxy Statement. The Filing Persons have also today filed a revised preliminary proxy statement on Schedule
PRRN14A (the “Revised Preliminary Proxy Statement”), which contains revisions intended to, among other matters, address
the Staff’s comments.

The responses set forth in
this letter are numbered to correspond to the numbered comments in the Comment Letter. For convenience of reference, we have also included
in each case the text of the applicable comment from the Comment Letter in bold face type immediately before the Filing Persons’
response thereto.

PREC14A Filed April 8, 2024

General Comments, page 1

1. Under the heading ‘Incorporation by Reference,’ we note that you
direct shareholders to the Company’s definitive proxy statement (when filed) for “[i]nformation concerning the date by which
shareholder proposals intended to be presented at the next annual meeting of shareholders must be received by the Company for inclusion
in the Company Proxy Statement.” Please revise to provide the disclosure required by Rule 14a-5(e) with respect to director nominations
for next year’s annual meeting.

Response: The Filing
Persons are relying on Rule 14a-5(c) to satisfy their obligation with respect to the disclosures required by Rule 14a-5(e),
including the disclosures required by Rule 14a-5(e) with respect to director nominations for next year’s annual meeting, by
making a reference to the Company’s definitive proxy statement which, when filed, is expected to contain such information. In
response to the Staff’s comment, the Filing Persons have revised the “Incorporation by Reference” section to more
specifically reference director nominations.

April 15, 2024

2. On the preliminary proxy card, you indicate that the proxy card will be voted
based on the GK Parties’ recommendations if the proxy card does not specify how the proxy should be voted. Please revise to clarify
whether you are describing an entirely unmarked, but signed proxy card, or one that is signed and marked as to other matters but not marked
as to the particular proposal addressed in your disclosure.

Response: In response to
the Staff’s comment, the Filing Persons have revised the preliminary proxy card to state that (i) if a stockholder signs and returns
an entirely unmarked proxy card and does not specify how the proxy should be voted with respect to any of the proposals, the proxy card
will be voted in the manner specified by the GK Parties and (ii) if a stockholder only provides voting instructions with respect to some,
but not all, of Proposals 1 through 4, the proxy card will be voted in accordance with the stockholders instructions on the Proposals
for which the stockholder provided specific instructions, and in the manner specified by the GK Parties with respect to any Proposals
for which the stockholder has not provided specific instructions.

Questions and Answers Relating
to this Proxy Solicitation, page 13

3. On page 17 of the Proxy Statement, you indicate that record holders of the Common
Stock can vote their shares by completing the BLUE proxy card or “by instructing us by telephone or via the Internet as to how you
would like your shares voted (instructions are on your BLUE universal proxy card [sic].” The preliminary proxy card does not appear
to provide record holders of the Common Stock with instructions on how to vote by telephone or via the Internet. Please revise or advise.

Response: In response to
the Staff’s comment, the Filing Persons have updated the preliminary proxy card to provide record holders of the Common Stock with
instructions on how to vote by telephone and via the Internet.

Proposal No. 1 - Election
of Directors, page 19

4. On page 20 of the Proxy Statement, you state that the Company’s non-chairman
directors were each granted RSUs “with respect to 7,288 shares of Common Shares, representing a grant having a dollar value of $100,000
based on such closing price” according to the Company Proxy Statement. Please revise to state the grant date of these RSUs.

Response: In response to
the Staff’s comment, the Filing Persons have revised the disclosure on page 20 of the Revised Preliminary Proxy to include May 16,
2023 as the grant date of the RSUs.

***

We hope that the foregoing has been
responsive to the Staff’s comments. Please do not hesitate to contact me at 212-504-6404 or Richard Brand at 212-504-5757 with any
questions or further comments you may have regarding this filing or if you wish to discuss the above.

    -2-

April 15, 2024

    Sincerely,

    /s/
    Kiran S. Kadekar

    Kiran
    S. Kadekar, Esq.

Via-E-mail:

  cc:
  GK Investor LLC

Richard M. Brand, Esq., Cadwalader, Wickersham
 & Taft LLP

    -3-