SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 17, 2025

Gregory Zikos
Chief Financial Officer
Costamare Inc.
7 Rue du Gabian
MC 98000 Monaco

 Re: Costamare Inc.
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed February 20, 2025
 File No. 001-34934
Dear Gregory Zikos:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Energy &
Transportation
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 July 10, 2025

 Costamare Inc.
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed February 20, 2025
 File No. 001-34934

 Dear Mr. Wojciechowski and Mr. Rodriguez:

 Reference is made to the comment letter (the “ Comment Letter ”) dated June 10, 2025 from the staff (the “ Staff ”) of the Division of Corporation Finance of the Securities and Exchange
 Commission (the “ Commission ”) with respect to the Report on Form 20-F for the fiscal year ended December 31, 2024, filed by Costamare Inc. (the “ Company ”) with the Commission via EDGAR on February 20, 2025.  The
 Company has today filed with the Commission, via EDGAR, this letter which sets forth the Company’s response to the comment contained in the Comment Letter.

 The numbered paragraph and heading below correspond to the heading set forth in the Comment Letter.  The Staff’s comments are set forth in bold, followed by the Company’s response to those
 comments.  Capitalized terms used in this letter but not defined herein have the meaning given to such terms in the Form 20-F.

 Form 20-F for the Fiscal Year ended December 31, 2024

 Operating and Financial Review and Prospects, page 70

 1.

 We note that you include Segmental Financial Information on page 80 although do
 not discuss or analyze the financial results of each segment, as would ordinarily be necessary to comply with Item 5 of Form 20-F. This requires explanations and assessments, along with quantitative and qualitative
 descriptions of the reasons underlying material changes, and states that information provided “...also must relate to all separate segments and/or other subdivisions (e.g., geographic areas, product lines) of the
 company [and]...must include other statistical data that the company believes will enhance a reader’s understanding of the company’s financial condition, cash flows and other changes in financial condition, and results
 of operations.”

 Please expand your disclosures to discuss and analyze the results of operations of each reportable segment, including the associated non-financial statistical details that are
 correlated with those operations, to address the requirements referenced above.

 Given your disclosure on page 55, explaining that having a large fleet of containerships with varying TEU capacities has enhanced your relationships with charterers by enabling them
 to efficiently serve the East-West, North-South and Intraregional trade routes, which has in turn allowed you to operate in the different rate environments prevailing for those routes, also indicate how your segment results of
 operations are correlated with each of these trade routes and describe the effects of the various rate environments, along with any related trends and uncertainties.

 Response:

 The Company acknowledges the Staff’s comment and confirms that in future filings, the Company will expand its disclosure to further discuss and analyze the results of operations of each reportable
 segment, along with any related trends and uncertainties.

 As an example, set forth below is the Company’s proposed additional disclosure regarding the results of operations of each reportable segment for 2024.  The Company expects to include substantially
 similar additional disclosures in the Report on Form 20-F for the fiscal year ending December 31, 2025 . On May 6, 2025, the Company completed the spin-off of its dry bulk vessels segment
 and Costamare Bulkers Inc. (“ CBI ”) segment into a standalone public company, Costamare Bulkers Holdings Limited. As such, the disclosure below only discusses the results of operations of the Company’s container vessels
 segment and Neptune Maritime Leasing Limited (“ NML ”) segment, the Company’s two remaining reportable segments following completion of the spin-off.

 “Year ended December 31, 2024 compared to year ended December 31, 2023 – Container vessels segment

 During the years ended December 31, 2024 and 2023, we had an average of 68.0 and 67.6 container vessels, respectively, in our owned fleet.

 During the year ended December 31, 2023, we (i) sold our 49% equity interest in the company owning the 2018-built, 3,800 TEU capacity containership,  Polar Argentina  to York Capital, (ii) acquired the 51% equity interest of York Capital in the 2018-built, 3,800 TEU capacity containership  Polar Brasil  and as a result we
 obtained 100% of the equity interest in the vessel and (iii) acquired the 51% equity interest of York Capital in the 2001-built, 1,550 TEU capacity containership  Arkadia  and as a result we
 obtained 100% of the equity interest in the vessel.

 In addition, during the year ended December 31, 2023, we sold the container vessels Maersk Kalamata , Sealand
 Washington and Oakland with an aggregate TEU capacity of 18,182.

 In the years ended December 31, 2024 and 2023, our containership fleet ownership days totaled 24,888 and 24,677 days, respectively.

 Total Voyage Revenue

 Total voyage revenue for the container vessels segment increased by 3.0%, or $25.2 million, to $864.6 million during the year ended December 31, 2024, from $839.4 million during the
 year ended December 31, 2023. The increase is mainly attributable to (i) decreased fleet off-hire and idle days in the year ended December 31, 2024 compared to the year ended December 31, 2023, (ii) revenue earned by two container
 vessels acquired during the second and fourth quarter of 2023, respectively and (iii) contractual reimbursements from certain of our charterers for EU Emissions Allowances (EUAs), since January 1, 2024; partly offset by revenue
 not earned by one container vessel sold during the year ended 2023.

 2

 Voyage Expenses

 Voyage expenses for the container vessels segment were $25.8 million and $12.5 million for the years ended December 31, 2024 and 2023, respectively. Voyage expenses increased, year
 over year, mainly due to the recognition of liabilities for EUAs and relevant expenses, since January 1, 2024. However, a significant portion of these liabilities are contractually reimbursed by the charterers, as discussed in “Total Voyage Revenue”, mitigating the impact on the Segment net expenses. Voyage expenses mainly include (i) fuel consumption, (ii) third-party commissions, (iii) port expenses, (iv) canal
 tolls and (v) EUAs liabilities.

 Voyage Expenses - related parties

 Voyage expenses - related parties were $12.2 million and $11.9 million for the years ended December 31, 2024 and 2023, respectively. Voyage expenses - related parties for the
 container vessels segment represent (i) fees of 1.25%, in the aggregate, on voyage revenues earned by our owned containership fleet charged by a related manager and a related service provider and (ii) charter brokerage fees (in
 respect of our container vessels) payable to two related charter brokerage companies for an amount of approximately $1.5 million and $1.4 million, in the aggregate, for the years ended December 31, 2024 and 2023, respectively.

 Vessels’ Operating Expenses

 Vessels’ operating expenses for the container vessels segment, which also include the realized gain/(loss) under derivative contracts entered into in relation to foreign currency
 exposure, were $158.2 million and $161.2 million during the years ended December 31, 2024 and 2023, respectively. Daily container vessels’ operating expenses were $6,355 and $6,531 for the years ended December 31, 2024 and 2023,
 respectively. Daily operating expenses are calculated as container vessels’ operating expenses for the period over the ownership days of the period.

 Interest and Finance Costs

 Interest and finance costs were $99.5 million and $117.0 million during the years ended December 31, 2024 and 2023, respectively. The decrease is mainly attributable to the
 decreased interest expense due to a lower average loan balance for the container vessels segment during the year ended December 31, 2024 compared to the year ended December 31, 2023.

 Other Segment Items

 Other segment items for the container vessels segment include depreciation expense of the containership vessels and amortization of dry-docking and special survey costs for the
 containership vessels.

 3

 Depreciation expense for the container vessels segment for the years ended December 31, 2024 and 2023 was $126.8 million and $126.7 million, respectively.

 Amortization of deferred dry-docking and special survey costs for the container vessels segment was $17.3 million and $15.3 million during the years ended December 31, 2024 and
 2023, respectively. During the year ended December 31, 2024, seven container vessels underwent and completed their dry-docking and special survey and one container vessel was in the process of completing her dry-docking and
 special survey. During the year ended December 31, 2023, 15 container vessels underwent and completed their dry-docking and special survey and one container vessel was in the process of completing her dry-docking and special
 survey.

 Year ended December 31, 2024 compared to year ended December 31, 2023 – NML

 Income from investments in leaseback vessels

 Income from investments in leaseback vessels was $23.9 million and $8.9 million for the years ended December 31, 2024 and 2023, respectively. Increased income from investments in
 leaseback vessels, year over year, is attributable to (i) the income earned from NML’s operations for the entire year ended December 31, 2024 (in 2023, we earned income from NML’s operations starting from the second quarter of
 2023) and (ii) the increased volume of NML’s operations during the year ended December 31, 2024 compared to the year ended December 31, 2023. NML acquires, owns and bareboat charters out vessels through its wholly-owned
 subsidiaries.

 Interest and Finance Costs

 Interest and finance costs for NML were $10.1 million and $2.2 million during the years ended December 31, 2024 and 2023, respectively. The increase is mainly attributable to the
 higher average loan balance for the NML segment in the year ended December 31, 2024 compared to the year ended December 31, 2023.”

 Neither the Company’s results of operations nor the results of operations of any of its segments are directly correlated to any of the East-West, North-South or Intra-regional trade routes. While the
 impact of being able to operate in a number of different routes is not reliably quantifiable, in future filings, the Company will revise its disclosure to explain how being able to operate in different routes impacts its
 relationships with charterers and its ability to efficiently serve them, and related trends and uncertainties.

 As an example, the Company proposes to replace in future filings the second paragraph on page 55 of the Form 20-F with the disclosure below.

 “We believe that the containership sector of the international shipping industry is characterized by the significant time required to develop the operating expertise and
 professional reputation necessary to obtain and retain customers. Our large and diversified fleet, comprised of containerships of varying TEU capacities, enables us to act as a one-stop solution for our charterers. This
 flexibility allows us to meet over time the changing operational needs of our clients across a broad spectrum of trade routes—ranging from East-West to North-South and Intraregional—which depend on, among other things, the
 availability of vessels for chartering at any given time, geopolitical developments such as changes to trade policies, the closure of the Suez Canal or sanctions, port congestion, infrastructure constraints such as limits on
 Panama Canal crossings, and regulatory changes such as changes to regulations regarding emissions or fuel types. Our versatile fleet allows us to offer commercial solutions that align with the shifting logistical and commercial
 requirements of different routes, enabling us to support our clients in optimizing their network and responding effectively to shifting market conditions; however, given the interplay of the aforementioned variables, the impact of
 rate environments on our results may vary significantly over time.  In the past decade, we have had successful chartering relationships with the majority of the top 10 liner companies by TEU capacity.”

 4

 On behalf of the Company, please allow us to express our appreciation of your attention to this matter.  Should you have any questions or comments with respect to this response letter, please contact D.
 Scott Bennett at 212-474-1132.

 Sincerely,

 /s/ D. Scott Bennett

 D. Scott Bennett

 5

 Mr. Mark Wojciechowski and Mr. Gus Rodriguez
 Division of Corporation Finance
 Office Of Energy & Transportation
 Securities and Exchange Commission
 100 F Street, NE
 Washington, D.C. 20549-0001

 Copy to:
 Mr. Gregory Zikos
 Chief Financial Officer
 Costamare Inc.
 7 rue du Gabian
 MC 98000 Monaco

 6

CORRESP
 1
 filename1.htm

 July 3, 2025

 Costamare Inc.
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed February 20, 2025
 File No. 001-34934

 Dear Mr. Wojciechowski and Mr. Rodriguez:

 Reference is made to the comment letter (the “ Comment Letter ”) dated June 10, 2025 from the staff (the “ Staff ”) of the Division of Corporation Finance of the Securities and Exchange
 Commission (the “ Commission ”) with respect to the Report on Form 20-F for the fiscal year ended December 31, 2024, filed by Costamare Inc. (the “ Company ”) with the Commission via EDGAR on February 20, 2025.

 As discussed with the Staff on July 3, 2025, the Company hereby confirms that it intends to provide its response to the Staff’s comments on or before July 11, 2025.

 We are grateful for the Staff’s assistance in this matter.  Please do not hesitate to contact me with any further comments or questions.

 Sincerely,

 /s/ D. Scott Bennett

 D. Scott Bennett

 Mr. Mark Wojciechowski and Mr. Gus Rodriguez
 Division of Corporation Finance
 Office Of Energy & Transportation
 Securities and Exchange Commission
 100 F Street, NE
 Washington, D.C. 20549-0001

 Copy to:
 Mr. Gregory Zikos
 Chief Financial Officer
 Costamare Inc.
 7 rue du Gabian
 MC 98000 Monaco

 2

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 10, 2025

Gregory Zikos
Chief Financial Officer
Costamare Inc.
7 Rue du Gabian
MC 98000 Monaco

 Re: Costamare Inc.
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed February 20, 2025
 File No. 001-34934
Dear Gregory Zikos:

 We have reviewed your filing and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe
the comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Fiscal Year ended December 31, 2024
Operating and Financial Review and Prospects, page 70

1. We note that you include Segmental Financial Information on page 80
although do
 not discuss or analyze the financial results of each segment, as would
ordinarily be
 necessary to comply with Item 5 of Form 20-F. This requires explanations
and
 assessments, along with quantitative and qualitative descriptions of the
reasons
 underlying material changes, and states that information provided
"...also must relate
 to all separate segments and/or other subdivisions (e.g., geographic
areas, product
 lines) of the company [and]...must include other statistical data that
the company
 believes will enhance a reader s understanding of the company s
financial condition,
 cash flows and other changes in financial condition, and results of
operations."

 Please expand your disclosures to discuss and analyze the results of
operations of each
 reportable segment, including the associated non-financial statistical
details that are
 correlated with those operations, to address the requirements referenced
above.
 June 10, 2025
Page 2

 Given your disclosure on page 55, explaining that having a large fleet
of
 containerships with varying TEU capacities has enhanced your
relationships with
 charterers by enabling them to efficiently serve the East-West,
North-South and Intra-
 regional trade routes, which has in turn allowed you to operate in the
different rate
 environments prevailing for those routes, also indicate how your segment
results of
 operations are correlated with each of these trade routes and describe
the effects of the
 various rate environments, along with any related trends and
uncertainties.

 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.

 Please contact Mark Wojciechowski at 202-551-3759 or Gus Rodriguez at
202-551-
3752 if you have questions regarding comments on the financial statements and
related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

    Securities and Exchange Commission

    Division of Corporation Finance

    100 F Street, N.E.

    Washington, D.C. 20549

            Attention:

            Ms. Cheryl Brown

            Mr. Daniel Morris

            Division of Corporation Finance

            Office of Energy & Transportation

    April 8, 2024

            Re:

            Costamare Inc.

            Registration Statement on Form F-3 (Registration No. 333-278366)

    Dear Ms. Brown and Mr. Morris:

    Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Costamare Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration
      Statement on Form F‑3 (Registration No. 333-278366), as amended (the “Registration Statement”), so that the Registration Statement may become effective by 4:00 pm (Eastern time) on April 10, 2024, or as soon as practicable thereafter.

    In connection with this request, the Company acknowledges that:

          ●

            should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the
              filing;

          ●

            the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing;
              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.

    It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform D. Scott Bennett at (212) 474-1132 and then send written confirmation to the addressees listed on the cover of
      the Registration Statement.

            Very truly yours,

            Costamare Inc.

            By

          /s/ Anastassios Gabrielides

            Name:

            Anastassios Gabrielides

            Title:

            General Counsel and Secretary

    [Signature Page to Acceleration Request]

United States securities and exchange commission logo
April 5, 2024
Konstantinos Konstantakopoulos
Chief Executive Officer
Costamare Inc.
7 rue du Gabian
MC 98000 Monaco
Re:Costamare Inc.
Registration Statement on Form F-3
Filed March 29, 2024
File No. 333-278366
Dear Konstantinos Konstantakopoulos:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Cheryl Brown at 202-551-3905 or Daniel Morris at 202-551-3314 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       D. Scott Bennett, Esq.

CORRESP
1
filename1.htm

    Securities and Exchange Commission

    Division of Corporation Finance

    100 F Street, N.E.

    Washington, D.C. 20549

            Attention:

            Karina Dorin

            Division of Corporation Finance

            Office of Transportation and Leisure

    March 23, 2021

            Re:

            Costamare Inc.

            Registration Statement on Form F-3 (Registration No. 333-254266)

    Dear Ms. Dorin:

    Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), Costamare Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on
      Form F‑3 (Registration No. 333-254266), as amended, so that the Registration Statement may become effective by 5:00 pm (Eastern time) on March 25, 2021, or as soon as practicable thereafter.

    In connection with this request, the Company acknowledges that:

          ●

            should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the
              filing;

          ●

            the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing;
              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.

    It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform D. Scott Bennett at (212) 474-1132 and then send written confirmation to the addressees listed on the cover of
      the Registration Statement.

            Very truly yours,

            Costamare Inc.

            By

            /s/ Anastassios Gabrielides

            Name:

            Anastassios Gabrielides

            Title:

            General Counsel and Secretary

      [Signature Page to Acceleration Request]

United States securities and exchange commission logo
March 22, 2021
Anastassios Gabrielides
General Counsel and Secretary
Costamare Inc.
7 rue du Gabian
MC 98000 Monaco
Re:Costamare Inc.
Registration Statement on Form F-3
Filed March 15, 2021
File No. 333-254266
Dear Mr. Gabrielides:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Karina Dorin, Staff Attorney, at (202) 551-3763 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       D. Scott Bennett

July 25, 201 9
Via E-mail
Konstantinos Konstantakopoulos
Chief Executive  Officer
Costamare Inc .
7 rue de Gabian
MC 98000 Monaco

 Re: Costamare Inc .
  Form 20-F for the Fiscal Year Ended December 31, 201 8
  Filed March 7 , 2019
  File No. 1 -34934

Dear Mr. Konstantakopoulos :

We refer you to our comment letter  dated  July 8, 2019  regarding business contacts with
Sudan .  We have completed our review of this subject matter.  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 .

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  C. Scott Bennett, Esq.
  Cravath , Swaine & Moore  LLP

  Anne Parker
  Assistant Director

CORRESP
1
filename1.htm

July 16, 2019

Costamare Inc.

Form 20-F for the year ended December 31, 2018

Filed March 7, 2019

File No. 001-34934

Dear Ms. Blye:

We refer to the letter of July 8, 2019 (the “Comment
Letter”), from the U.S. Securities and Exchange Commission (the “SEC”) to Costamare Inc. (the “Company”)
setting forth the comments of the SEC staff (the “Staff”) on the Company’s Form 20-F for the year ended
December 31, 2018 (the “Form 20-F”), filed with the SEC via EDGAR on March 7, 2019. The Company has today filed
with the SEC, via EDGAR, this letter which sets forth the Company’s responses to the comments contained in the Comment Letter.

The numbered paragraph and heading below correspond
to the heading set forth in the Comment Letter. The Staff’s comments are set forth in bold, followed by the Company’s
response to those comments. Capitalized terms used in this letter but not defined herein have the meaning given to such terms in
the Form 20-F.

Form 20-F for the Year Ended December 31,
2017

Item 3. Key Information

Risk Factors

Risks Inherent in Our Business

Our vessels may call on ports located in
countries that are subject to restrictions . . ., page 29

    1.
    You do not provide information about port calls to Sudan. Publicly available information about some of the companies you identify as charterers indicates that those companies have offices in, and shipping routes that include, Sudan. Sudan is designated by the U.S. Department of State as a state

    sponsor of terrorism, and it is subject to U.S. export controls. Please describe to us the nature and extent of any past, current, and anticipated contacts with Sudan during the past three fiscal years and the subsequent interim period, including contacts with Sudan’s’ government, whether through subsidiaries, charterers, affiliates, or other direct or indirect arrangements. Discuss for us the materiality of any such contacts, in quantitative terms and in terms of qualitative factors that a reasonable investor would deem important in making an investment decision. Tell us the approximate dollar amounts of any revenues, assets and liabilities associated with Sudan for the last three fiscal years and the subsequent interim period.

Response:

The Company has a fleet of 71 containerships
that are registered or flagged in countries other than the U.S. and are under time charter contracts. The Company, the containerships
themselves and the charterers of the vessels are non-U.S. persons. Pursuant to the time charter contracts, the charterer may operate
the relevant vessel within the limitations set forth in the charter contract. Each charterer of a Company vessel directs the route
and the loading and discharge ports for the vessel. All of the Company’s charter contracts (1) require each vessel to be
employed in lawful trades and (2) prohibit each vessel from calling on ports located in specified countries which are subject to
sanctions and/or any other ports, if such calls would be in violation of U.N. or other countries’ sanctions, including U.S.
international sanctions applicable to non-U.S. persons.

Therefore, it is possible that charterers may
engage in legally permitted trading in locations which may still be subject to sanctions or boycott. From time to time, solely
on charterers’ instructions, and subject to the restrictions in the charter contracts, the Company’s vessels have called
and may again call at ports located in countries subject to sanctions and embargoes imposed by the U.S., the E.U., the U.N. and
other governments and their agencies, including countries subject to U.S. export controls. The Company made 39 and 4 port calls
to Sudan in 2016 and 2017, respectively, out of a total of approximately 32,964 calls in 2016 and approximately 39,800 calls in
2017, respectively. The Company has made no port calls to Sudan after May 31, 2017 and does not currently plan or expect to make
any further port calls to Sudan. The Company had no revenues, assets or liabilities associated with Sudan in 2018 or the subsequent
interim period, and, as illustrated by the number of port calls per year, the Company does not believe that the revenue amounts
associated with Sudan in 2016 and 2017 are either qualitatively or quantitatively material.

The Company has not provided and does not intend
to provide any goods or services, whether directly or indirectly, to the governments of, or entities controlled by the government
of Sudan. In addition, the Company has not had any agreements, commercial arrangements, or other contacts with the government and/or
entities controlled by the government of Sudan, and does not intend to enter into such agreements, arrangements or other contacts
in the future.

2

Other

The Company hereby acknowledges
to the Commission that:

    ·
    the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ·
    Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

    ·
    the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

*          *          *

On behalf of the Company, please allow us to express
our appreciation of your attention to this matter. Should you have any questions or comments with respect to this response letter,
please contact D. Scott Bennett at 212-474-1132.

    Sincerely,

/s/ D. Scott Bennett

Ms. Cecilia Blye

Division of Corporation Finance

Office Of Global Security Risk

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-0001

VIA EDGAR

3

Copy to:

Mr. Gregory G. Zikos

Chief Financial Officer

Costamare Inc.

7 rue du Gabian

MC98000 Monaco

Via
e-mail

4

July 8, 201 9
Via E-mail
Konstantinos Konstantakopoulos
Chief Executive  Officer
Costamare Inc .
7 rue de Gabian
MC 98000 Monaco

 Re: Costamare Inc .
  Form 20-F for the Fiscal Year Ended December 31, 201 8
  Filed March 7 , 2019
  File No. 1 -34934

Dear Mr. Konstantakopoulos :

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our comments , we ask you to provide us with information so we may better
understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Risk Factors, page 3
Our vessels may call on ports located in countries that are subject to restrictions…, page 29

1. You do not provide information  about port calls to Sudan.  Publicly available information
about some of the companies you identify as charterers indicates that those companies have
offices in, and shipping routes that include, Sudan.  Sudan is  designated by the U.S.
Department of State  as a state sponsor of terrorism , and it is subject to U.S. export controls.
Please describe to us the nature and extent of any past, current, and anticipated contacts with
Sudan during the past three fiscal years and the subsequent interim period, includ ing contacts
with Sudan’s’ government, whether through subsidiaries, charterers, affiliates, or other direct
or indirect arrangements.  Discuss for us the materiality of any such contacts, in quantitative
terms and in terms of qualitative factors that a re asonable investor would deem important in
making an investment decision.  Te ll us the approximate dollar amounts of any revenues,
assets and liabilities associated with Sudan for the last three fiscal years and the subsequent
interim period .

Konstantinos Konstantakopoulos
Costamare Inc.
 July 8, 2019
 Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

Sincerely,

 /s/ Cecilia Bl ye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  C. Scott Bennett, Esq.
  Cravath , Swaine & Moore  LLP

  Anne Parker
  Assistant Director

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Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Susan Block

Division of Corporation Finance

Office of Transportation and Leisure

February 6, 2019

Re:

Costamare Inc.

Registration Statement on Form F-3 (Registration No. 333-228457)

Dear Ms. Block:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Costamare Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form F‑3 (Registration No. 333-228457), as amended, so that the Registration Statement may become effective by 5:00 pm (Eastern time) on February 8, 2019, or as soon as practicable thereafter.

In connection with this request, the Company acknowledges that:

●

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

●

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; 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.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform D. Scott Bennett at (212) 474-1132, and then send written confirmation to the addressees listed on the cover of the Registration Statement.

Very truly yours,

Costamare Inc.

By:

/s/ Anastassios Gabrielides

Name:  Anastassios Gabrielides

Title:    General Counsel and Secretary

February 5, 2019
Gregory Zikos
Chief Financial Officer
Costamare Inc.
7 rue du Cabian
MC 98000 Monaco
Re:Costamare Inc.
Form 20-F for the Year Ended December 31, 2017
Filed February 27, 2018
File No. 001-34934
Dear Mr. Zikos:
            We have completed our review of your filings.  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.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure
cc:       A. Gabrielides

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December 19, 2018

Costamare Inc.

Registration Statement on Form F-3

Filed November 19, 2018

File No. 333-228457

Dear Ms. Block & Ms. Parker:

We refer to the letter of December 11,
2018 (the “Comment Letter”), from the U.S. Securities and Exchange Commission (the “SEC”)
to Costamare Inc. (the “Company” or “we”) setting forth the comments of the SEC staff (the
“Staff”) on the Company’s Registration Statement on Form F-3 (the “Registration Statement”),
filed with the SEC via EDGAR on November 19, 2018. The Company has today filed with the SEC, via EDGAR, this letter and Amendment
No. 1 (“Amendment No. 1”) to the Registration Statement. This letter and Amendment No. 1 set forth the Company’s
responses to the comments contained in the Comment Letter.

The numbered paragraphs and headings below
correspond to those headings set forth in the Comment Letter. Each of the Staff’s comments is set forth in bold, followed
by the Company’s response to each comment. Capitalized terms used in this letter but not defined herein have the meaning
given to such terms in the Amendment No. 1.

Form F-3 filed November 19, 2018

Selling Shareholders, page 6

 1. We note your disclosure that Costamare Inc. entered into a share purchase agreement with some of the selling shareholders
that permits Costamare, upon serving a share settlement notice at any time within six months of the effective date of this registration
statement, to elect to pay a portion of the consideration under the share purchase agreement in common stock. Given Costamare may
elect to pay consideration under the agreement in common stock in the future, please provide us your analysis as to why that transaction

would be considered a completed private placement such that it is appropriate to register the resale of those shares now. Refer
generally to Question 134.01 of the Securities Act section of the Compliance and Disclosure Interpretations, available on our website
at www.sec.gov.

Response:

The Company respectfully submits that
the private placement of the shares (the “Shares”) to the selling shareholders named in the Registration Statement
is “complete” since the selling shareholders made their investment decision with respect to the Shares by entering
into the Share Purchase Agreement, dated November 12, 2018 (the “Share Purchase Agreement”). Upon entry into
the Share Purchase Agreement, the selling shareholders have been irrevocably bound to accept as partial consideration, at the sole
discretion of the Company, a number of Shares which corresponds to a specified percentage of the purchase price of the vessels,
which is subject only to the satisfaction of conditions outside the control of the selling shareholders. Accordingly, the Company
believes that, consistent with SEC Securities Act Section CD&I Question 134.01, the sale of the Shares to the selling shareholders
pursuant to the Share Purchase Agreement should be deemed “completed” and that the selling shareholders have been at
“market risk” with respect to the Shares from the date of entry into the Share Purchase Agreement, which was prior
to the filing of the Registration Statement.

As you are aware, the Securities Act
Section CD&I Question 134.01 provides in relevant part for the purposes of this letter that:

The resale registration statement may be filed if securities
are privately placed, with the closing of the private placement contingent on filing or effectiveness of a resale registration
statement. At the time of filing the registration statement, the purchasers in the private placement must be irrevocably bound
to purchase the securities subject only to the filing or effectiveness of the registration statement or other conditions outside
their control, and the purchase price must be established at the time of the private placement. The purchase price cannot be contingent
on the market price at the time of effectiveness of the registration statement.

The Company believes that each of the
elements cited in Question 134.01 in order for the Registration Statement to cover securities yet to be issued is satisfied, namely
that:

 · the selling shareholders were “irrevocably bound” to acquire the Shares at the
time of execution of the Share Purchase Agreement which was prior to the filing of the Registration Statement;

 · such obligations are not subject to conditions within the selling shareholder’s control;

 · the purchase price of the Shares was established at the time of execution of the Share Purchase
Agreement, when the selling shareholders became bound to acquire the Shares; and

 · there is no contingency based on market price that would allow the selling shareholders the
right to not accept the shares.

Upon entry into the Share Purchase Agreement,
the selling shareholders became obligated, upon receipt of a share settlement notice at any time within six months of the effective
date of this Registration Statement, to accept the Shares. The selling shareholders are irrevocably committed to purchasing the
Shares as they have no new investment discretion in determining whether to accept the Shares the Company issues. The number of
Shares being registered corresponds to the maximum percentage of the purchase price the Company, in its sole discretion, may contractually
require the selling shareholders to accept, as partial consideration for the acquisition of the vessels.

General

 2. Please explain to us why you are registering a dollar amount, rather than the number of shares offered for resale. As part
of your response, please explain the authority you are relying upon to register a dollar amount, rather than the number of shares.
We may have further comment once we review your response.

Response:

In response to the Staff’s comment,
the Company has amended the Registration Statement accordingly to register a number of shares for resale, in lieu of a dollar amount
of shares for resale.

 3. Please confirm your understanding that you should clear any outstanding SEC staff comments on your Form 20-F (File No. 001-34934)
for fiscal year end December 31, 2017, filed on February 27, 2018, before requesting an acceleration of effectiveness of this registration
statement.

Response:

We acknowledge the Staff's comment
and confirm our understanding.

Other

The Company hereby acknowledges
to the Commission that:

 · the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 · Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action
with respect to the filing; and

 · the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

*	*	*

On behalf of the Company, please allow
us to express our appreciation of your attention to this matter. Should you have any questions or comments with respect to this
response letter, please contact D. Scott Bennett at 212-474-1132.

    Sincerely,

    /s/
    D. Scott Bennett

Ms. Susan Block

Special Counsel

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-0001

VIA EDGAR

Copy to:

Mr. Gregory G. Zikos

Chief Financial Officer

Costamare Inc.

7 rue due Gabian

98000 MC, Monaco

Via
e-mail

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December 19, 2018

Costamare Inc.

Form 20-F for the year ended December 31, 2017

Filed February 27, 2018

Form 6-K

Furnished October 24, 2018

File No. 001-34934

Dear Ms. Simpson:

We refer to the letter of December 10,
2018 (the “Comment Letter”), from the U.S. Securities and Exchange Commission (the “SEC”)
to Costamare Inc. (the “Company”) setting forth the comments of the SEC staff (the “Staff”)
on the Company’s Form 20-F for the year ended December 31, 2017 (the “Form 20-F”), filed with the SEC
via EDGAR on February 27, 2018 and the Company’s Form 6-K, furnished to the SEC on October 24, 2018 (the “Form 6-K”).
The Company has today filed with the SEC, via EDGAR, this letter which sets forth the Company’s responses to the comments
contained in the Comment Letter.

The numbered paragraphs and headings below
correspond to those headings set forth in the Comment Letter. Each of the Staff’s comments is set forth in bold, followed
by the Company’s response to each comment. Capitalized terms used in this letter but not defined herein have the meaning
given to such terms in the Registration Statement.

Form 6-K furnished October 24, 2018

Exhibit 99.1 Earnings Release, page 1

 1. We note that in your earnings release furnished on October 24, 2018 as Exhibit 99.1 of Form 6-K, you disclose adjusted net
income available to common stockholders and adjusted net income available to common stockholders per share. Please revise to include
disclosure of the most directly comparable GAAP measure, net income. See Regulation G.

Response:

The Company acknowledges the Staff’s
comment and it will revise Exhibit 99.1 in its future earnings releases to include a reconciliation of adjusted net income available
to common stockholders and adjusted net income available to common stockholders per share to the most directly comparable GAAP
measure. These reconciliations have been provided in Exhibit 99.2, and our future earnings releases will include similar reconciliations
in Exhibit 99.1.

Form 20-F for the Year Ended December 31, 2017

Item 5. Operating and Financial Review and Prospects

Critical Accounting Policies

Vessel Impairment, page 86

 2. We note your disclosure on page 86 that an internal analysis, which used a discounted cash flow model utilizing inputs and
assumptions based on market observations as of December 31, 2017, suggests that 29 of your 52 vessels in the water may have current
market values below their carrying value. We also note that you have disclosed a table of those vessels and the aggregate amount
by which the carrying value exceeds the market value. In light of the fact that market values appear to be based on discounted
cash flows which are based on assumptions which are highly subjective, please tell us what consideration was given to utilizing
charter free shipbroker values, adjusted for existing time charters, to determine market value. Also, we note that the first paragraph
on page 86 appears to indicate that you take into consideration third party valuations in determining fair value of the vessels.
As it relates to the 7 vessels that failed Step 1 of the impairment analysis in 2017, please clarify
for us how fair value is determined in Step 2 of the impairment analysis. Additionally, with respect to the underlying undiscounted
cash flow portion of the analysis, please:

 · Confirm that a growth rate is not applied to estimated future inflows for charter free days.

 · Considering the depressed rates in most recent years, please elaborate on your basis that the ten year historical average
rates represent a full shipping cycle. As part of your response, please provide us with a chart showing the ten year shipping cycle,
and what you have considered as outliers to be removed from the analysis.

 · Tell us whether a useful life of 30 years is applied throughout the estimated future cash flows and why, when during the
year ended December 31, 2017 and the subsequent period ended September 30, 2018 several dispositions for demolition have been taking
place prior to the 30 year mark.

 2

Response:

Impairment Analysis (according to US GAAP)

As background on the Company’s approach
to its impairment analysis we note the following.

 (i) The Company reviews its vessels for impairment whenever events or changes in circumstances indicate
that the carrying amount of a vessel might not be recoverable. The Company considers information, such as vessel sales and purchases,
business plans and overall market conditions in order to determine if an impairment might exist.

 (ii) If the Company determines that an impairment indicator is present or if circumstances indicate
that an impairment may exist, the Company then performs an analysis to determine whether an impairment loss should be recognized.
The Company proceeds to Step 1 of the impairment analysis whereby, as discussed in further detail on page 85 of the Company’s
Form 20-F, it computes estimates of future undiscounted cash flows for each vessel based on assumptions regarding time charter
rates, vessels’ operating expenses, vessels’ capital expenditures, vessels’ residual value, fleet utilization
and the estimated remaining useful life of each vessel. The assumptions used to develop estimates of future undiscounted cash flows
are based on historical trends as well as future expectations. If those undiscounted net operating cash flows are greater than
a vessel’s carrying value, there are no impairment indications for such vessel. If those undiscounted net operating cash
flows are not greater than a vessel’s carrying value, the Company proceeds to Step 2 of the impairment analysis for such
vessel.

 (iii) In Step 2 of the impairment analysis, the Company determines the fair value of the vessels
that failed Step 1 of the impairment analysis, based on management estimates and assumptions, making use of available market data
and taking into consideration third party valuations. The difference between the carrying value of the vessels that failed Step
1 of the impairment analysis and their fair value as calculated in Step 2 of the impairment analysis is recognized in the Company’s
accounts as impairment loss.

In particular, as it relates to the seven vessels
that failed Step 1 of the impairment analysis in 2017, the Company proceeded to Step 2 of the impairment analysis and determined
the fair market value of those vessels by utilizing third party charter free valuations. As further discussed above, management
reviewed such valuations by considering factors such as the current vessels’ sale and purchase market condition and concluded
that the valuations were fair and thus could be used to determine the impairment loss amount.

3

Internal Analysis and Use of Charter Free Shipbroker Values

As explained in the Company’s Form 20-F
on pages 87-88, the Company conducts an internal analysis and provides a table disclosing all instances where the carrying values
of its vessels exceed their estimated fair market value as calculated by the internal analysis. The Company uses third party valuations
in its internal analysis and performs the following procedures in order to prepare the disclosure:

 (i) for vessels with charters expiring within the 12 months following the date of the annual financial
statements (December 31, 2017), the Company uses charter free third party valuations as at December 31, 2017; and

 (ii) for all other vessels, the Company uses: (A) third party charter free valuations of each vessel
at the earliest expiry date of the charter of each vessel (e.g., in determining the residual value of a 5-year old vessel
with a time charter having its earliest expiry date five years after the date of the annual financial statements, the third party
valuation provides us with the charter free value of a 10-year old vessel with the same technical characteristics and specifications,
which is representative of the residual value of the vessel at the earliest expiry date of the respective time charter) discounted
to the date of the annual financial statements (December 31, 2017) plus (B) the discounted future cash flow from the charter of
each vessel until the earliest expiry date of the charter.

The Company also advises the Staff that under
the majority of the Company’s credit facilities, independent third-party lenders have contractually agreed with the Company
that the same internal analysis discussed above under (i) and (ii) for purposes of vessel valuation is appropriate for determining
compliance with the relevant covenants in its credit facilities.

Future Inflows Growth Rate

The Company confirms that no growth rate is applied to estimated
future inflows for charter free days.

Basis for Ten-Year Historical Average Rates

Since 2010, the Company has consistently used
the ten-year historical average rates in its impairment analysis, which it believes, given the high volatility in the shipping
market, is representative of a full shipping cycle. In the Company’s analysis, it utilizes monthly data over a ten-year period
derived from the Alphaliner Containership Index, a commonly used fee-based, third-party source in the containership industry which
the Company will supplementally provide to the Staff, after eliminating outliers, which the Company defines as index values that
fall outside plus or minus one standard deviation from the average index value over the ten-year period.

4

Appropriateness of 30 Year Useful Life of Vessels

The Company intends to hold and operate its
vessels up to the end of their useful life, which it believes to be generally 30 years. Many other publicly-traded container companies
also follow this 30-year useful life convention (e.g., Seaspan Corporation, Danaos Corporation, Global Ship Lease Inc. and
Diana Containerships). Therefore, the Company applies a 30-year useful life throughout the estimated future cash flows.

The Company examines the prospect and the timing
of each vessel sale for demolition opportunistically and on a case by case basis. The decision to sell a specific vessel for demolition
depends on the prospects of the vessel to secure employment, the estimated cost of maintaining the vessel, the available financing
and the price of scrap. Since 2010, the Company has sold 21 vessels for demolition at an average age of 27.1 years.

Other

The Company hereby acknowledges
to the Commission that:

 · the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 · Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action
with respect to the filing; and

 · the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

*	*	*

On behalf of the Company, please allow
us to express our appreciation of your attention to this matter. Should you have any questions or comments with respect to this
response letter, please contact D. Scott Bennett at 212-474-1132.

    Sincerely,

    /s/ D.
    Scott Bennett

Ms. Effie Simpson

Division of Corporation Finance

Office Of Transportation and Leisure

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-0001

VIA EDGAR

5

Copy to:

Mr. Gregory G. Zikos

Chief Financial Officer

Costamare Inc.

7 rue du Gabian

MC98000 Monaco

Via
e-mail

6

December 11, 2018
Konstantinos Konstantakopoulos
Chief Executive Officer
Costamare Inc.
7 rue du Gabian
MC 98000 Monaco
Re:Costamare Inc.
Registration Statement Filed on Form F-3
Filed November 19, 2018
File No. 333-228457
Dear Mr. Konstantakopoulos:
            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 F-3 filed November 19, 2018
Selling Shareholders, page 6
1.We note your disclosure that Costamare Inc. entered into a share purchase agreement with
some of the selling shareholders that permits Costamare, upon serving a share settlement
notice at any time within six months of the effective date of this registration statement, to
elect to pay a portion of the consideration under the share purchase agreement in common
stock.  Given Costamare may elect to pay consideration under the agreement in common
stock in the future, please provide us your analysis as to why that transaction would be
considered a completed private placement such that it is appropriate to register the resale
of those shares now.  Refer generally to Question 134.01 of the Securities Act Section of
the Compliance and Disclosure Interpretations, available on our website at www.sec.gov.

 FirstName LastNameKonstantinos  Konstantakopoulos
 Comapany NameCostamare Inc.
 December 11, 2018 Page 2
 FirstName LastName
Konstantinos  Konstantakopoulos
Costamare Inc.
December 11, 2018
Page 2
General
2.Please explain to us why you are registering a dollar amount, rather than the number of
shares being offered for resale.  As part of your response, please explain the authority you
are relying upon to register a dollar amount, rather than the number of shares.  We may
have further comment once we review your response.
3.Please confirm your understanding that you should clear any outstanding SEC staff
comments on your Form 20-F (file no. 001-34934) for fiscal year end December 31, 2017,
filed on February 27, 2018, before requesting an acceleration of effectiveness of this
registration statement.
            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 Susan Block at 202-551-3210 or Anne Parker, Assistant Director, at 202-
551-3611 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure

December 10, 2018
Gregory Zikos
Chief Financial Officer
Costamare Inc.
7 rue du Cabian
MC 98000 Monaco
Re:Costamare Inc.
Form 20-F for the Year Ended December 31, 2017
Filed February 27, 2018
Form 6-K for the Period Ended September 30, 2018
Furnished October 24, 2018
File No. 001-34934
Dear Mr. Zikos:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 6-K furnished October 24, 2018
Exhibit 99.1 Earnings Release, page 1
1.We note that in your earnings release furnished on October 24, 2018 as Exhibit 99.1 of
Form 6-K, you disclose adjusted net income available to common stockholders and
adjusted net income available to common stockholders per share.  Please revise to include
disclosure of the most directly comparable GAAP measure, net income.  See Regulation
G.

 FirstName LastNameGregory Zikos
 Comapany NameCostamare Inc.
 December 10, 2018 Page 2
 FirstName LastNameGregory Zikos
Costamare Inc.
December 10, 2018
Page 2
Form 20-F for the Year Ended December 31, 2017
Item 5. Operating and Financial review and Prospects
Critical Accounting Policies
Vessel Impairment, page 86
2.We note your disclosure on page 86 that an internal analysis, which used a discounted
cash flow model utilizing inputs and assumptions based on market observations as of
December 31, 2017, suggests that 29 of your 52 vessels in the water may have current
market values below their carrying value.  We also note that you have disclosed a table of
those vessels and the aggregate amount by which the carrying value exceeds the market
value.  In light of the fact that market values appear to be based on discounted cash flows
which are based on assumptions which are highly subjective, please tell us what
consideration was given to utilizing charter free shipbroker values, adjusted for existing
time charters, to determine market value.  Also, we note that the first paragraph on page
86 appears to indicate that you take into consideration third party valuations in
determining fair value of the vessels.  As it relates to the 7 vessels that failed Step 1 of the
impairment analysis in 2017, please clarify for us how fair value is determined in Step 2
of the impairment analysis.  Additionally, with respect to the underlying undiscounted
cash flow portion of the analysis, please:
•Confirm that a growth rate is not applied to estimated future inflows for charter free
days.
•Considering the depressed rates in most recent years, please elaborate on your basis
that the ten year historical average rates represent a full shipping cycle.  As part of
your response, please provide us with a chart showing the ten year shipping cycle, and
what you have considered as outliers to be removed from the analysis.
•Tell us whether a useful life of 30 years is applied throughout the estimated future cash
flows and why, when  during the year ended December 31, 2017 and the subsequent
period ended September 30, 2018 several dispositions for demolition have been taking
place prior to the 30 year mark.

 FirstName LastNameGregory Zikos
 Comapany NameCostamare Inc.
 December 10, 2018 Page 3
 FirstName LastName
Gregory Zikos
Costamare Inc.
December 10, 2018
Page 3
            In closing, 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.
            You may contact Effie Simpson at (202) 551-3346 or Claire Erlanger at (202) 551-3301
with any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure
cc:       A. Gabrieliedes

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Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

 Washington, D.C. 20549

Attention:

Donald E. Field

Division of Corporation Finance

Office of Transportation and Leisure

March 15, 2018

Re:

Costamare Inc.

Registration Statement on Form F-3 (Registration No. 333-223392)

Dear Mr. Field:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), Costamare Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form F‑3 (Registration No. 333-223392), as amended, so that the Registration Statement may become effective by 4:00 pm (Eastern time) on March 16, 2018, or as soon as practicable thereafter.

In connection with this request, the Company acknowledges that:

·

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; 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.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform D. Scott Bennett at (212) 474-1132 or Elizabeth A. Morgan at (212) 474-1474, and then send written confirmation to the addressees listed on the cover of the Registration Statement.

Very truly yours,

Costamare Inc.

By:

/s/ Anastassios Gabrielides

Name:  Anastassios Gabrielides

Title:    General Counsel and Secretary

March 13, 2018
Konstantinos Konstantakopoulos
Chief Executive Officer
Costamare Inc.
7 rue du Gabian
MC 98000 Monaco
Re:Costamare Inc.
Registration Statement on Form F-3
Filed March 2, 2018
File No. 333-223392
Dear Mr. Konstantakopoulos:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Donald Field at (202) 551-3680 with any questions.
Division of Corporation Finance
Office of Transportation and Leisure

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COSTAMARE INC.

MARSHALL ISLANDS

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:
Loan Lauren P. Nguyen

Special Counsel

November 26, 2013

Re:
Costamare Inc.

Registration Statement on Form F-3 (Registration No. 333-191833)

Dear Ms. Nguyen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), Costamare Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form F-3 (Registration No. 333-191833), as amended, so that the Registration Statement may become effective by 3:00 pm (Eastern time) on November 27, 2013, or as soon as practicable thereafter.

In connection with this request, the Company acknowledges that:

●

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

●

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; 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.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform William P. Rogers, Jr. at (212) 474-1270, and then send written confirmation to the addressees listed on the cover of the Registration Statement.

Very truly yours,

Costamare Inc.

By:

/s/ Anastassios Gabrielides

Name: Anastassios Gabrielides

Title:   General Counsel and Secretary

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(212) 474-1270

November 20, 2013

Costamare Inc.

Registration Statement on Form F-3

Filed October 21, 2013

File No. 333-191833

Dear Ms. Nguyen:

We refer to the letter of November 15, 2013 (the “Comment Letter”), from the U.S. Securities and Exchange Commission (the “SEC”) to Costamare Inc. (the “Company”) setting forth the comments of the SEC staff (the “Staff”) on the Company’s Registration Statement on Form F-3 (the “Registration Statement”), filed with the SEC via EDGAR on October 21, 2013.  The Company has today filed with the SEC, via EDGAR, this letter and Amendment No. 1 (“Amendment No. 1”) to the Registration Statement.  This letter and Amendment No. 1 set forth the Company’s responses to the comments contained in the Comment Letter.

Four clean copies of Amendment No. 1 and four copies of Amendment No. 1 that have been marked to show changes made to the Registration Statement (“Marked Registration Statement”) are enclosed for your convenience along with four copies of this letter.

The numbered paragraphs and headings below correspond to those headings set forth in the Comment Letter.  Each of the Staff’s comments is set forth in bold, followed by the Company’s response to each comment. Capitalized terms used in this letter but not defined herein have the meaning given to such terms in Amendment No. 1.

General

1.

Please confirm that in connection with any future offerings of securities pursuant to this registration statement you will file unqualified opinions of counsel no later than the closing date of the offering of securities covered by the registration statement.

Response:

The Company confirms that, in connection with any future offerings of securities pursuant to the Registration Statement, it will file unqualified opinions of counsel no later than the closing date of the offering of securities covered by the Registration Statement.

Registration Statement Cover Page

2.

We note your disclosure in footnote 1 to the Calculation of Registration Fee table that “[s]eparate consideration may or may not be received for shares that are issuable on exercise, conversion or exchange of other securities or that are issued in units.” To the extent that separate consideration is to be received, please confirm that the aggregate amount of such consideration will be included in the aggregate offering price of all securities sold. Refer to Rule 457(i) of the Securities Act of 1933, as amended.

Response:

The Company confirms that, to the extent separate consideration of the type referred to above is received, the aggregate amount of such consideration will be included in the aggregate offering price of all securities sold.  Furthermore, we have added the following sentence to the disclosure in footnote 1 to the Calculation of Registration Fee table, as shown on the cover of the Marked Registration Statement:

“To the extent that separate consideration is received for any such securities, the aggregate amount of such consideration will be included in the aggregate offering price of all securities sold.”

Global Securities, page 14

3.

We note the disclosure that you may issue debt securities in the form of registered global securities. However, the global securities are not listed in the registration statement fee table, the prospectus cover page or in the legality opinion. Please confirm your understanding that any global securities will be considered separate securities from the deposited securities, the offering of which will require separate registration under the Securities Act of 1933 or an exemption from such registration. In this regard, please tell us whether you intend to register the offering of the global securities under this registration statement.

Response:

We respectfully advise the Staff that the discussion under the heading “Global Registered Securities” sets out the method by which debt securities are issued and held by the nominee for the Depository Trust Company (“DTC”), which maintains the central depository and clearing system for securities traded in the public markets in the U.S.  Virtually all publicly held U.S. dollar denominated debt securities are held in this manner.  The use of the term “registered” is merely a reference to the form in which the securities are held by DTC, and to distinguish them from bearer securities, which is the form in which the European securities depositaries, Clearstream Banking, société anonyme (“Clearstream”), and Euroclear System (“Euroclear”), hold securities deposited in the clearing systems maintained by those entities.

2

We do not believe that the global securities described in the referenced section are separate securities from the securities being registered under the Securities Act of 1933, as amended (the “‘33 Act”).  As more fully discussed above, such section merely explains the form that the debt securities being registered under the ‘33 Act may take.  That section is not describing a situation where the Company deposits an underlying security (such as a common or preferred stock) with a bank or other institution acting as a depositary for the issue, and causes the bank or other entity to issue a depositary receipt or depositary share representing a interest in the deposited security, often a fraction of a share, or a greater number of shares.  Where such depositary receipts or shares are issued, it is the depositary receipt or share that is in turn deposited in the clearing system maintained by DTC, Clearstream or Euroclear.

Separately, we advise the Staff that the Registration Statement has been modified to reflect that the preferred stock registered under the Registration Statement may be represented by American Depositary Shares (“ADSs”).  A separate registration statement on Form F-6 will be filed in respect of any ADSs in the event that ADSs are issuable on deposit of an issue of preferred stock.  The Company has also added a description of ADSs to the Registration Statement, as shown on pages 17 and 18 of the Marked Registration Statement.

Other

The Company hereby acknowledges to the Commission that:

·

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

·

Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

·

the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

*           *           *

3

On behalf of the Company, please allow us to express our appreciation of your attention to this matter.  Should you have any questions or comments with respect to this response letter, please contact William P. Rogers, Jr. at 212-474-1270.

Sincerely,

/s/ William P. Rogers, Jr.

William P. Rogers, Jr.

Ms. Loan Lauren P. Nguyen

Special Counsel

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-0001

VIA EDGAR

Copy to:

Mr. Gregory G. Zikos

Chief Financial Officer

Costamare Inc.

60 Zephyrou Street & Syngrou Avenue

17564 Athens Greece

VIA E-MAIL

 4

November 15 , 2013

Via E -mail
Konstantinos Konstantakopoulos
Chief Executive Officer
Costamare Inc.
60 Zephyrou Street &
Syngrou Avenue
17564 Athens, Greece

Re: Costamare Inc.
  Registration Statement on Form F-3
  Filed October 21 , 2013
  File No. 333-191833

Dear Mr. Konstantakopoulos :

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 .  Where 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.

General

1. Please confirm that in connection with any future offerings of securities pursuant to this
registration statement you will file unqualified opinions of counsel no later than the
closing date of the offe ring of securities covered by the registration statement.

Registration Statement Cover Page

2. We note your disclosure in footnote 1 to the Calculation of Registration Fee table that
“[s]eparate consideration may or may not be received for shares that are i ssuable on
exercise, conversion or exchange of other securities or that are issued in units.”  To the
extent that separate consideration is to be received , please confirm that the aggregate
amount of such consideration will be included in the aggregate off ering price of all
securities sold.  Refer to Rule 457(i) of the Securities Act of 1933 , as amended .

Konstantinos Konstantakopoulos
Costamare Inc.
November 15 , 2013
Page 2

Global Securities, page 14

3. We note the disclosure that you may issue debt securities in the form of registered global
securities.  However, the global securities are not listed in the registration statement fee
table, the prospectus cover page or in the legality opinion.  Please confirm your
understanding that any global securities will be considered separate securities from the
depos ited securities, the offering of which will require separate registration under the
Securities Act of 1933 or an exemption from such registration.  In this regard, please tell
us whether you intend to register the offering of the global securities under th is
registration statement.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules requ ire.  Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it d oes not foreclose the Commission from taking any act ion with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibi lity for
the adequacy and accuracy of th e disclosure in the filing; 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 la ws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acce leration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Konstantinos Konstantakopoulos
Costamare Inc.
November 15 , 2013
Page 3

 Please contact Donald E. Field at (202) 551 -3680 or me at (202) 551 -3642  with any
questions.

Sincerely,

/s/ Loan Lauren P. Nguyen

Loan Lauren P. Nguyen
Special Counsel

cc: Via E -mail
 William P. Rogers, Jr., Esq.
 Cravath, Swaine & Moore LLP

January 22, 2013

Via E -mail
Mr. Gregory Zikos
Costamare Inc.
Chief Financial Officer
60 Zephyrou Street &  Syngrou Avenue
17564 Athens Greece

Re: Costamare Inc.
 Form 20-F for the year  ended December 31, 2011
Filed February 29, 2012
File No. 001 -34934

Dear Mr. Zikos :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission  from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pe rsons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ David R. Humphrey

David R. Humphrey
Accounting  Branch Chief

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January 10, 2013

Costamare Inc.

Form 20-F for the year ended December 31, 2011

Filed February 29, 2012

File No. 001-34934

Dear Mr. Humphrey:

We refer to the letter of December 28, 2012 (the “Comment Letter”), from the U.S. Securities and Exchange Commission (the “SEC”) to Costamare Inc. (the “Company”) setting forth the comments of the SEC staff (the “Staff”) on the Company’s Form 20-F for the year ended December 31, 2011 (the “2011 20-F”), filed with the SEC via EDGAR on February 29, 2012.  We respectfully submit this response on behalf of the Company.

The numbered paragraphs and headings below correspond to those headings set forth in the Comment Letter.  Each of the Staff’s comments are set forth in bold, followed by the Company’s response to each comment. Capitalized terms used in this letter but not defined herein have the meaning given to such terms in the 2011 20-F.

Critical Accounting Policies – Vessel Impairment, page 70

1.

We note that, in developing estimates of undiscounted future cash flows, management utilizes an estimated daily time charter equivalent for your vessels’ unfixed days based on the most recent ten year historical average rates, adjusted for inflation.  It appears the nature of this assumption is both material and susceptible to change.  For this reason, please tell us and expand your narrative on an ongoing basis to also discuss whether your estimated future undiscounted cash flows would exceed each of your vessels’ carrying values if management were to utilize an estimated daily time charter equivalent for your vessels’ unfixed days based on the most recent five year, three year or one year historical average rates without adjusting for inflation.

Response:

The Company confirms that it will revise its disclosure of its impairment analysis in future filings to also discuss whether the estimated future undiscounted cash flows would exceed each of its vessels’ carrying value if the most recent five year, three year and one year historical average rates without adjusting for inflation were utilized for the vessels’ unfixed days.

The Company has prepared revised proposed disclosure attached as Appendix I. The Company advises the Staff that it intends to include disclosure substantially in this form in its 2012 annual report on Form 20-F.

Critical Accounting Policies, page 73

 2.

On page 73, you indicate that the aggregate carrying value of seven of your vessels, assessed separately, exceeds their aggregate basic charter-free market value by approximately $46.8 million.  On an ongoing basis, please discuss this matter on a comparative basis.  Please provide a draft of your intended revised disclosure with your response.

Response:

The Company confirms that it will prepare its disclosure in future filings so as to include a comparative analysis of how the carrying values of the Company’s vessels compare to the charter-free market value of such vessels as of each balance sheet date presented in the financial statements included in the relevant annual report on Form 20-F.

The Company has prepared revised proposed disclosure attached as Appendix I. The Company advises the Staff that it intends to include disclosure substantially in this form in its 2012 annual report on Form 20-F.

Other

The Company hereby acknowledges to the Commission that:

·

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

·

Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

  2

·

the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

*           *           *

    On behalf of the Company, please allow us to express our appreciation of your attention to this matter.  Should you have any questions or comments with respect to this response letter, please contact William P. Rogers, Jr. at 212-474-1270.

Sincerely,

/s/ William P. Rogers, Jr.

William P. Rogers, Jr.

Mr. David R. Humphrey

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-0001

VIA EDGAR

Copy to:

Mr. Gregory G. Zikos

Chief Financial Officer

Costamare Inc.

60 Zephyrou Street & Syngrou Avenue

17564 Athens Greece

VIA E-MAIL

3

Appendix I

The disclosure in this Appendix I is marked to show changes to the disclosure in the 2011 20-F.

Vessel Impairment

We evaluate the carrying amounts of our vessels to determine if events have occurred that would require modification to their carrying values or useful lives. In evaluating useful lives and carrying values of long-lived assets, we review certain indicators of potential impairment, such as undiscounted projected operating cash flows, vessel sales and purchases, business plans and overall market conditions.

The economic and market conditions as at December 31, 2010 and 2011, including the significant disruptions in the global credit markets in the prior years, had broad effects on participants in a wide variety of industries. 2011 saw increasing charter rates and asset prices during the first six months of the year, along with further growth in vessel supply, followed by steep declines in both charter rates and vessel values during the latter half of the year, due to reduced transportation demand triggered by the unfolding sovereign debt crisis and overall financial volatility, conditions that we consider indicators of impairment.

In developing estimates of future undiscounted cash flows, we make assumptions and estimates about the vessels’ future performance, with the significant assumptions being related to time charter rates, vessels’ operating expenses, vessels’ capital expenditures, vessels’ residual value, fleet utilization, and the estimated remaining useful life of each vessel. The assumptions used to develop estimates of future undiscounted cash flows are based on historical trends as well as future expectations and taking into consideration growth rates.

We determine undiscounted projected net operating cash flows for each vessel and compare it to the vessel’s carrying value. Consistent with prior years and to the extent impairment indicators were present, the projected net operating cash flows are determined by considering the charter revenues from existing time charters for the fixed fleet days and an estimated daily time charter rate for the unfixed days (based on the most recent ten year historical average rates, inflated annually by a 4.0% growth rate being the historical and forecasted average world GDP nominal growth rate) over the remaining estimated life of the vessel assumed to be 30 years from the delivery of the vessel from the shipyard, expected outflows for vessels’ operating expenses assuming an annual inflation rate of 2.93% (in line with the average world Consumer Price Index forecasted), planned dry-docking and special survey expenditures, management fees expenditures which are adjusted every year, after December 31, 2012 as provided under the Group Management Agreement, by an inflation rate of 4.0% and fleet utilization of 99.3% (excluding the scheduled off-hire days for planned dry-dockings and special surveys which are determined separately ranging from 14 to 25 days depending on size and age of each vessel) based on historical experience. The salvage value used in the impairment test is estimated to be in the range from $150 to $250 per light weight ton in accordance with our vessels’ depreciation policy.

Based on our analysis, the undiscounted projected net operating cash flows for each vessel were in excess compared to each vessel’s carrying value, and accordingly, step two of the impairment analysis was not required and no impairment of vessels existed as of December 31, 2010 2011 and 2011.2012.

As noted above, we determine projected cash flows for unfixed days using an estimated daily time charter rate based on the most recent ten year historical average rates, inflated annually by a 4.0% growth rate. We consider this approach to be reasonable and appropriate. However, charter rates are subject to change based on a variety of factors that we cannot control and we note that charter rates over the last few years have been, on average, below their historical ten year average. If as at December 31, 2011 and 2012 we were to utilize an estimated daily time charter equivalent for our vessels’ unfixed days based on the most recent five year, three year or one year historical average rates without adjusting for inflation (or another growth assumption), the results would be the following:

December 31, 2011

December 31, 2012

No of vessels (*)

Amount (**)

No of vessels (*)

Amount (**)

5-year historical average rate

1

6 million

3-year historical average rate

6

29 million

1-year historical average rate

1

9 million

   (*) Number of vessels that their carrying value would not have been recovered.

   (**) Aggregate carrying value that would not have been recovered.

An internal analysis, which used a discounted cash flow model utilizing inputs and assumptions based on market observations as of December 31, 2011,2012, suggests that seven[ ] of our 46 [ ] vessels in the water may have current market values below their carrying values (seven of our 46 vessels in the water as at December 31, 2011). However, we believe that, with respect to these seven[ ] vessels, each of which is currently under time charter, we will recover their carrying values through the end of their useful lives, based on their undiscounted cash flows. We currently do not expect to sell any of these vessels, or otherwise dispose of them, significantly before the end of their estimated useful life.

Although we believe that the assumptions used to evaluate potential impairment are reasonable and appropriate, such assumptions are highly subjective. There can be no assurance as to how long charter rates and vessel values will remain at their current low levels or whether they will improve by any significant degree. Charter rates may remain at depressed levels for some time which could adversely affect our revenue and profitability, and future assessments of vessel impairment.

While the Company intends to continue to hold and operate its vessels, the following table presents information with respect to the carrying amount of the Company’s vessels and indicates whether their estimated market values based on an internal discounted cash flow analysis are below their carrying values as of December 31, 2012 and 2011. The carrying value of each of the Company’s vessels does not necessarily represent its fair market value or the amount that could be obtained if the vessel were sold. The Company’s estimates of market values assume that the vessels are all in good and seaworthy condition without need for repair and, if inspected, would be certified as being in class without recommendations of any kind. In addition, because vessel values are highly volatile, these estimates may not be indicative of either the current or future prices that the Company could achieve if it were to sell any of the vessels. The Company would not record an impairment for any of the vessels for which the fair market value is below its carrying value unless and until the Company either determines to sell the vessel for a loss or determines that the vessel’s carrying amount is not recoverable. The Company believes that the undiscounted projected net operating cash flows over the estimated remaining useful lives for those vessels that have experienced declines in estimated market values below their carrying values exceed such vessels’ carrying values as of December 31, 2011,2012, and accordingly has not recorded an impairment charge.

Vessel

Capacity

(TEU)

Built

Acquisition Date

Carrying Value

December 31, 2011

($ US Million)(1)

Carrying Value

December 31, 2012

($ US Million)(1)

1

Cosco Hellas

9469
2006

July 2006

79.6

2

Cosco Guangzhou

9469
2006

February 2006

78.4

3

Cosco Beijing

9469
2006

June 2006

79.2

4

Cosco Yantian

9469
2006

April 2006

79.1

5

Cosco Ningbo

9469
2006

March 2006

78.5

6

MSC Navarino*

8531
2010

May 2010

116.0

7

Maersk Kure

7403
1996

December 2007

80.7

8

Maersk Kokura

7403
1997

February 2008

82.4

9

Maersk Kawasaki

7403
1997

December 2007

82.1

10

MSC Methoni

6724
2003

October 2011

59.5

11

Sealand Michigan

6648
2000

October 2000

41.8

12

Sealand Illinois

6648
2000

December 2000

42.0

13

Sealand NY

6648
2000

May 2000

40.5

14

Sealand Washington

6648
2000

August 2000

41.5

15

Maersk Kobe

6648
2000

June 2000

40.9

16

Maersk Kalamata

6644
2003

June 2003

50.3

17

Maersk Kingston

6644
2003

April 2003

50.2

18

Maersk Kolkata

6644
2003

January 2003

49.7

19

MSC Romanos

5050
2003

August 2011

54.2

20

Zim Shanghai

4992
2002

October 2002

36.4

21

Zim New York

4992
2002

September 2002

36.1

22

Zim Pireaus

4992
2004

May 2004

36.1

23

Halifax Express

4890
2000

November 2000

33.6

24

Oakland Express

4890
2000

October 2000

33.2

25

Singapore Express

4890
2000

August 2000

32.9

26

MSC Mykonos

4828
1988

January 2005

23.8

27

MSC Mandraki

4828
1988

October 2004

23.2

28

MSC Antwerp

3883
1993

December 1999

14.4

29

MSC Kyoto

3874
1981

May 2003

5.7

30

MSC Washington

3874
1984

September 1999

5.5

31

MSC Austria

3576
1984

March 1998

5.0

32

Karmen*

3351
1991

November 2010

12.4

33

Marina*

3351
1992

February 2011

10.9

34

Konstantina*

3351
1992

March 2011

10.7

35

Akritas

3152
1987

November 1997

5.9

36

Gather

2922
1984

December 2007

9.1

37

Genius I

2922
1984

September 2009

3.9

38

Gifted

2922
1984

August 2009

3.9

39

MSC Challenger

2633
1986

May 1998

5.2

40

MSC Reunion

2024
1992

March 2011

9.4

41

MSC Namibia II

2023
1991

March 2011

9.4

42

MSC Sierra II

2023
1991

March 2011

9.4

43

MSC Pylos

2020
1991

January 2011

7.5

44

Prosper*

1504
1996

March 2011

10.3

45

Zagora*

1162
1995

January 2011

7.9

46

Horizon*

1068
1991

February 2005

11.2

1,639.6

               (1)      For impairment test calculation, Carrying Value includes the unamortized balance of dry-docking cost as at December 31, 2011. 2011 and 2012.

*         Indicates container vessels which we believe, as of December 31, 2011,2011 and 2012, may have market values below their carrying values. TheAs at December 31, 2011 the aggregate carrying value of these seven vessels was $179.3 million, while we believe that their market value was approximately $132.5 million. As at December 31, 2012 the aggregate carrying value of [ ] vessels was $[ ] million, while we believe that their market value was approximately $[ ] million.

Vessels are stated at cost, which consists of the contract price and any material expenses incurred upon acquisition (initial repairs, improvements and delivery expenses, interest and on-site supervision costs incurred during the construction periods). Subsequent expenditures for conversions and major improvements are also capitalized when they appreciably extend the life, increase the earning capacity or improve the efficiency or safety of the vessels.

We depreciate our vessels based on a straight line basis over the expected useful life of each vessel, which is 30 years from the date of their initial delivery from the shipyard, which we believe is within industry standards and represents the most reasonable useful life for each of our vessels. Depreciation is based on the cost of the vessel less its estimated residual value. Secondhand vessels are depreciated from the date of their acquisition through their remaining estimated useful lives.

We review for impairment long-lived assets held and used whenever events or chan

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January 2, 2013

Costamare Inc.

Form 20-F for the Year Ended December 31, 2011

Filed February 29, 2012

File No. 001-34934

Dear Mr. Humphrey:

Reference is made to the comment letter (the “Comment Letter”) dated December 28, 2012 from the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) with respect to the annual report on Form 20-F of Costamare Inc. (the “Company”) for the year ended December 31, 2011, filed with the Commission on February 29, 2012.

In order to consider and fully respond to the comments raised by the Staff in the Comment Letter, the Company believes that it may require additional time beyond the ten business days referred to therein.  Accordingly, the Company respectfully advises the Staff that it will respond to the Comment Letter as soon as practicable and, in any event, currently expects to provide a response no later than January 18, 2013.

We are grateful for the Staff’s assistance in this matter.  Please do not hesitate to contact me with any further comments or questions.

Sincerely,

/s/ William P. Rogers, Jr.

William P. Rogers, Jr.

Mr. David R. Humphrey

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549-3561

VIA EDGAR

Copy to:

Mr. Gregory G. Zikos

Chief Financial Officer

Costamare Inc.

60 Zephyrou Street & Syngrou Avenue

17564 Athens, Greece

VIA EMAIL

2

December 28, 2012

Via E -mail
Mr. Gregory Zikos
Costamare Inc.
Chief Financial Officer
60 Zephyrou Street &  Syngrou Avenue
17564 Athens Greece

Re: Costamare Inc.
 Form 20-F for the year ended December 31, 2011
Filed February 29, 2012
File No. 001 -34934

Dear Mr. Zikos :

We have reviewed your filing an d have the following 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 within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply t o 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 filing and the information you provide in
response to these  comments, we may have  additional comment s.

Form 20 -F for the year ended December 31, 2011

Item 5. Operating and Financial Review and Prospects

Critical Accounting Policies  - Vessel Impairment, page 70

1. We note that, in developing estimates of undiscounted future cash flows, manag ement
utilizes an estimated daily time charter equivalent for your vessels’ unfixed days based on
the most recent ten year historical average rates, adjusted for inflation. It appears the
nature of this assumption is both material and susceptible to change . For this reason,
please tell us and expand your narrative on an ongoing basis to also discuss whether your
estimated future undiscounted cash flows would exceed each of your vessels’ carrying
values if management were to utilize an estimated daily time c harter equivalent for your
vessels’ unfixed days based on the most recent five year, three year or one year historical
average rates without adjusting for inflation.

Mr. Gregory Zikos
Costamare Inc.
December 28, 2012
Page 2

 2. On page 73, you indicate that the aggregate carrying value of seven of your vessels,
asses sed separately, exceeds their aggregate basic charter -free market value by
approximately $46.8 million. On an ongoing basis, please discuss this matter on a
comparative basis.  Please provide a draft of your intended revised disclosure with your
response.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Kristin Shifflett at 202 -551-3381  if you have qu estions regarding
comments on the financial statements and related matters.  Please contact me at 202-551-3211
with any other questions.

Sincerely,

 /s/ David R. Humphrey

David R. Humphrey
Accounting Branch Chief

January 31, 2012
 Via E-mail

Mr. Gregory G. Zikos   Chief Financial Officer Costamare Inc. 60 Zephyrou Street & Syngrou Avenue 17564, Athens, Greece
Re: Costamare Inc.
 Form 20-F for Fiscal Year Ended December 31, 2010  Filed March 22, 2011  File No. 001-34934

Dear Mr. Zikos:
We have completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.
 Sincerely,
/s/ David R. Humphrey
 David R. Humphrey Accounting Branch Chief

CORRESP
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January 17, 2012

Costamare Inc.

Form 20-F for the year ended December 31, 2010

Filed March 22, 2011

File No. 001-34934

Dear Mr. Humphrey:

We refer to the letter of December 21, 2011 (the “Comment Letter”), from the U.S. Securities and Exchange Commission (the “SEC”) to Costamare Inc. (the “Company”) setting forth the comments of the SEC staff (the “Staff”) on the Company’s Form 20-F for the year ended December 31, 2010 (the “2010 20-F”), filed with the SEC via EDGAR on March 22, 2011. We respectfully submit this response on behalf of the Company.

The numbered paragraphs and headings below correspond to those headings set forth in the Comment Letter.  Each of the Staff’s comments are set forth in bold, followed by the Company’s response to each comment. Capitalized terms used in this letter but not defined herein have the meaning given to such terms in the 2010 20-F.

Protection and Indemnity Insurance – Pollution coverage, page 36

1.

You indicate that, as a member of a P&I association, which is a member of the International Group, you will be subject to calls payable to the P&I association based on the International Group’s claim records, as well as the claim records of all other members of the association. In this regard, please disclose whether there is a cap on your liability exposure for calls payable to the P&I association and quantify such cap. In addition, please disclose the amount of any material call payables, or refunds received, for each reporting period. Also, please tell us the financial statement line item[s] that include[s] call payables to, or refunds received from, the P&I association.

2

Response: The Company respectfully advises the Staff that there is no cap on the Company’s liability exposure for calls payable to the P&I association.  However, based on the limited size and frequency of the assessment of calls payable to the P&I association historically, the Company does not believe these amounts to be material.  For the five years ended December 31, 2006, 2007, 2008, 2009 and 2010, the aggregate expenses included in the Company’s financial statements pursuant to calls payable to the P&I association were $0, $0, $1.29 million, $0 and $0, respectively. The aggregate expense for the five years period ended December 31, 2010 represents approximately 0.24% of the Company’s total Net income during that period. Furthermore, the aggregate expense for the year ended December 31, 2008 represents approximately 1.29% of the Company’s Net income during that period. Calls payable to the P&I association are included, being part of the vessel insurance expense, in the line item “Vessels’ operating expenses.”

Furthermore, based on communications that the Company has received from the P&I association, the P&I association assessed calls payable in only two of the last fifteen years prior to the year ended December 31, 2010.  As of December 31, 2011, the Company had not received notification of any calls payable to the P&I association during the year ended December 31, 2011.

The Company also notes that in the section “D. Risk Factors - Risks Inherent in Our Business” of the 2010 20-F under the heading “Our insurance may be insufficient to cover losses that may occur to our property or result from our operations,” it discloses that “we may also be subject to calls, or premiums, in amounts based not only on our own claim records but also the claim records of all other members of the protection and indemnity associations through which we receive indemnity insurance coverage.”

Item 5. Operating and Financial Review and Prospects, page 44

Critical Accounting Policies, page 67

Vessel Impairment, page 68

2.

You indicate that an internal analysis, which used a discounted cash flow model utilizing inputs and assumptions based on market observations as of December 31, 2010, suggests that five of your 43 vessels may have current market values below their carrying values. In this regard, please consider expanding your disclosure to include a table summarizing your owned vessels that details, by vessel, the date of acquisition, purchase price and carrying value at the balance sheet date. Please identify within this table those vessels whose estimated market values are less than their carrying values. In this regard, for those vessels whose market value is below their carrying value, please add disclosure below the table of the aggregate market value and aggregate book value of such vessels. This additional disclosure will provide investors with an indication of the estimated magnitude of the potential aggregate impairment charge related to these vessels, as of December 31, 2010, if you decided to sell all of such vessels. Also, the disclosure accompanying the table should discuss the related accounting treatment of your vessels, and describe the circumstances under which you would record an impairment loss for such vessels.

3

Response: The Company confirms that it will include in its future filings, commencing with the Company’s Form 20-F for the year ended December 31, 2011, a table listing the Company’s vessels by date of acquisition and carrying value at the balance sheet date and identifying those vessels whose estimated market value is below their carrying value.  The Company also confirms that the disclosure associated with the table will show the aggregate estimated market value and aggregate book value of the vessels whose estimated market value is below their carrying value as of the reporting date.  The Company respectfully advises the Staff that it does not believe disclosure of the purchase price of the Company’s vessels in the table would be meaningful to an investor’s determination of the estimated magnitude of the potential aggregate impairment charge since the carrying value of such vessels will be disclosed and is affected by items in addition to the purchase price, such as surveys and vessel improvements during dry dockings.  The disclosure associated with the table will also discuss the related accounting treatment of the Company’s vessels and the circumstances under which an impairment loss for such vessels would be recorded.

For your reference, the Company has attached as Annex A hereto for illustration purposes a sample table and the accompanying disclosure for the vessels owned by the Company as it would have appeared as of December 31, 2010.

Other

The Company hereby acknowledges to the Commission that:

●

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

●

Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

●

the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

4

*           *           *

On behalf of the Company, please allow us to express our appreciation of your attention to this matter.  Should you have any questions or comments with respect to this response letter, please contact William P. Rogers, Jr. at 212-474-1270.

Very truly yours,

/s/ William P. Rogers, Jr.

William P. Rogers, Jr.

Mr. David R. Humphrey

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-0001

VIA EDGAR

Copy to:

Mr. Gregory G. Zikos

Chief Financial Officer

Costamare Inc.

60 Zephyrou Street & Syngrou Avenue

17564, Athens Greece

  VIA E-MAIL

5

ANNEX A

While the Company intends to continue to hold and operate its vessels, the following table presents information with respect to the carrying amount of the Company’s vessels and indicates whether their estimated market values based on an internal discounted cash flow analysis, which incorporates the assumptions and estimates discussed under Critical Accounting Policies and in the Significant Accounting Policies included in our financial statements, are below their carrying values as of December 31, 2010. The carrying value of each of the Company’s vessels does not necessarily represent its fair market value or the amount that could be obtained if the vessel were sold. The Company’s estimates of market values assume that the vessels are all in good and seaworthy condition without need for repair and, if inspected, would be certified as being in class without notations of any kind. In addition, because vessel values are highly volatile, these estimates may not be indicative of either the current or future prices that the Company could achieve if it were to sell any of the vessels. The Company would not record an impairment for any of the vessels for which the fair market value is below its carrying value unless and until the Company either determines to sell the vessel for a loss or determines that the vessel’s carrying amount is not recoverable.  The Company believes that the undiscounted projected net operating cash flows over the estimated remaining useful lives for those vessels that have experienced declines in estimated market values below their carrying values exceed such vessels’ carrying values as of December 31, 2010, and accordingly has not recorded an impairment charge.

Vessel

Capacity (TEUs)

Built

Acquisition Date

Carrying Value ($ US Million)(1)

1

Cosco Hellas

9469

2006

July 2006

81.6

2

Cosco Guangzhou

9469

2006

February 2006

81.5

3

Cosco Beijing

9469

2006

June 2006

81.3

4

Cosco Yantian

9469

2006

April 2006

81.1

5

Cosco Ningbo

9469

2006

March 2006

80.7

6

MSC Navarino*

8531

2010

May 2010

119.8

7

Maersk Kure

7403

1996

December 2007

86.3

8

Maersk Kokura

7403

1997

February 2008

87.5

9

Maersk Kawasaki

7403

1997

December 2007

87.2

10

Sealand Michigan

6648

2000

October 2000

44.0

11

Sealand Illinois

6648

2000

December 2000

44.3

12

Sealand NY

6648

2000

May 2000

42.7

13

Sealand Washington

6648

2000

August 2000

43.7

14

Maersk Kobe

6648

2000

June 2000

43.1

15

Maersk Kalamata

6644

2003

June 2003

52.6

16

Maersk Kingston

6644

2003

April 2003

52.5

17

Maersk Kolkata

6644

2003

January 2003

51.9

18

Zim Shanghai

4992

2002

October 2002

38.1

19

Zim New York

4992

2002

September 2002

37.8

20

Zim Pireaus

4992

2004

May 2004

37.7

21

NY Express

4890

2000

November 2000

35.4

22

Oakland Express

4890

2000

October 2000

35.0

23

Singapore Express

4890

2000

August 2000

34.7

24

MSC Mykonos *

4828

1988

January 2005

26.9

25

MSC Mandraki *

4828

1988

October 2004

25.9

26

MSC Antwerp

3883

1993

December 1999

15.6

27

MSC Kyoto

3874

1981

May 2003

5.9

28

MSC Washington

3874

1984

September 1999

6.7

29

MSC Austria

3576

1984

March 1998

6.1

30

Rena

3351

1990

November 2010

11.2

31

Karmen

3351

1991

November 2010

11.7

32

Akritas *

3152

1987

November 1997

6.6

6

33

Gather

2922

1984

December 2007

11.3

34

Garden

2922

1984

December 2007

10.8

35

Genius

2922

1984

September 2009

4.0

36

Gifted

2922

1984

August 2009

4.0

37

MSC Challenger

2633

1986

May 1998

5.9

38

MSC Namibia

1652

1977

June 1993

2.9

39

MSC Sudan

1630

1976

September 1993

3.1

40

MSC Sierra

1630

1977

August 1993

2.4

41

MSC Tuscany

1468

1978

October 1991

1.7

42

MSC Fado

1181

1978

March 1988

1.8

43

Horizon*

1068

1991

February 2005

12.3

1,557.3

(1)

For impairment test calculation, Carrying Value includes the unamortized balance of dry-docking cost as at December 31, 2010.

*Indicates container vessels which we believe, as of December 31, 2010, may have market values below their carrying values. The aggregate carrying value of these five vessels was $191.5 million, while we believe that their market value was approximately $151.8 million.

Vessels are stated at cost, which consists of the contract price and any material expenses incurred upon acquisition (initial repairs, improvements and delivery expenses, interest and on-site supervision costs incurred during the construction periods). Subsequent expenditures for conversions and major improvements are also capitalized when they appreciably extend the life, increase the earning capacity or improve the efficiency or safety of the vessels.

We depreciate our vessels based on a straight line basis over the expected useful life of each vessel, which is 30 years from the date of their initial delivery from the shipyard, which we believe is within industry standards and represents the most reasonable useful life for each of our vessels. Depreciation is based on the cost of the vessel less its estimated residual value. Secondhand vessels are depreciated from the date of their acquisition through their remaining estimated useful lives.

We review for impairment long-lived assets held and used whenever events or changes in circumstances indicate that the carrying amount of the assets may not be recoverable. In this respect, we review our fleet for impairment on a vessel by vessel basis. When the estimate of undiscounted projected net operating cash flows, excluding interest charges, expected to be generated by the use of the vessel is less than its carrying amount, we evaluate the vessel for impairment loss. The impairment loss is determined by the difference between the carrying amount of the vessel and the fair value of the vessel. If our estimate of undiscounted projected net operating cash flows for any vessel is lower than the vessel’s carrying value, the carrying value is written down, by recording an impairment loss to operations, to the vessel’s fair market value if the fair market value is lower than the vessel’s carrying value.

CORRESP
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December 22, 2011

Costamare Inc.

Form 20-F for the Year Ended December 31, 2010

Filed March 22, 2011

File No. 001-34934

Dear Mr. Humphrey:

Reference is made to the comment letter (the “Comment Letter”) dated December 21, 2011 from the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) with respect to the annual report on Form 20-F of Costamare Inc. (the “Company”) for the year ended December 31, 2010, filed with the Commission on March 22, 2011.

In order to consider and fully respond to the comments raised by the Staff in the Comment Letter, the Company believes that it will require additional time beyond the ten business days referred to therein.  Accordingly, the Company respectfully requests an extension of the time to respond to the Comment Letter until January 20, 2012.

We are grateful for the Staff’s assistance in this matter.  Please do not hesitate to contact me with any further comments or questions.

Sincerely,

/s/ William P. Rogers, Jr.

Name:  William P. Rogers, Jr.

2

Mr. David R. Humphrey

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549-3561

VIA EDGAR

Copy to:

Mr. Gregory G. Zikos

Chief Financial Officer

Costamare Inc.

60 Zephyrou Street & Syngrou Avenue

17564, Athens, Greece

VIA EMAIL

December 21, 2011
 Via E-mail

Mr. Gregory G. Zikos
Chief Financial Officer
Costamare Inc. 60 Zephyrou Street & Syngrou Avenue 17564, Athens, Greece
Re: Costamare Inc.
 Form 20-F for the year ended December 31, 2010
Filed March 22, 2011 File No.
001-34934

Dear Mr. Zikos:
 We have reviewed your filing and have the following 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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 20-F for the fiscal year ended December 31, 2010

 Protection and Indemnity Insuranc e – Pollution coverage, page 36

 1. You indicate that, as a member of a P&I association, which is a member of the
International Group, you will be subject to call s payable to the P&I association based on
the International Group’s claim records,  as  well as the claim records of all other
members of the association.  In this regard, please disclose whether there is a cap on your
liability exposure for calls payable to the P&I association and quantify such cap.  In
addition, please disclose the amount of any ma terial call payables, or refunds received,
for each reporting period.  Also, please tell us the financial statement line item[s] that
include[s] call payables t o, or refunds received fro m, the P&I association.

Gregory G. Zikos
Costamare Inc.
December 21, 2011 Page 2

 Item 5.  Operating and Financial Review and Propects, page 44

 Critical Accounting Policies, page 67

 Vessel Impairment, page 68

 2. You indicate that an internal analysis, whic h used a discounted cash flow model utilizing
inputs and assumptions based on market obs ervations as of December 31, 2010, suggests
that five of your 43 vessels may have current market values below their carrying values.
In this regard, please consider expanding your  disclosure to include a table summarizing
your owned vessels that detail s, by vessel, the date of acquisition, purchase price and
carrying value at the balance sheet date.  Plea se identify within this table those vessels
whose estimated market values are less than their carrying values.  In this regard, for
those vessels whose market value is below their carrying value, please add disclosure
below the table of the aggregate market valu e and aggregate book value of such vessels.
This additional disclosure will provide inve stors with an indication of the estimated
magnitude of the potential aggregate impairment  charge related to these vessels, as of
December 31, 2010, if you decided to sell all of  such vessels.  Also, the disclosure
accompanying the table should discuss the re lated accounting treatment of your vessels,
and describe the circumstances under whic h you would record an impairment loss for
such vessels.  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Gregory G. Zikos
Costamare Inc.
December 21, 2011 Page 3

 You may contact Beverly A. Singleton at  (202) 551-3328 or Juan Migone, Review
Accountant, at (202) 551-3312 if you have que stions regarding comments on the financial
statements and related matters.  Please contac t me at (202) 551-3211 with any other questions.

Sincerely,
   /s/ David R. Humphrey
David R. Humphrey Accounting Branch Chief