Morgan Stanley & Co. Incorporated
1585 Broadway
New York, New York 10036
Dahlman Rose & Company, LLC
142 West 57th Street
New York, New York 10019
March 8, 2010
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street
Washington DC 20549-7010
Attention: Michelle Lacko, Esq.
Re: Baltic Trading Limited
Registration Statement on Form S-1 (File No. 333-162456)
Dear Sir or Madam:
Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we as representatives of the several Underwriters for the initial public offering of the common stock of Baltic Trading Limited (the Company), wish to advise you that the Companys Preliminary Prospectus issued February 26, 2010 was distributed during the period from February 26, 2010 through the date hereof, as follows:
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2,300 |
to |
7 |
Underwriters |
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100 |
to |
1 |
Dealer |
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1,392 |
to |
1,242 |
Institutions |
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26 |
to |
26 |
Others |
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Total: |
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3,818 |
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We were advised on January 7, 2010 by the Corporate Finance Department of the Financial Industry Regulatory Authority that it has reviewed the above-referenced proposed initial public offering and that it has determined to raise no objections with respect to the fairness of the terms and arrangements of the offering.
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, we hereby join in the Companys request for acceleration of the effective date of the above-referenced registration statement so that it becomes effective at 3:00 p.m. (E.S.T.) on March 9, 2010, or as soon as possible thereafter.
Very truly yours,
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Morgan Stanley & Co. Incorporated |
Dahlman Rose & Company, LLC |
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By: |
/s/ Kenneth Pott |
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By: |
/s/ Robert Brinberg |
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Name: Kenneth Pott |
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Name: Robert Brinberg |
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Title: Managing Director |
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Title: Chief Operating Officer |