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      August 15, 2007

Prokopios (Akis) Tsirigakis
Chief Executive Office and President
Star Bulk Carriers Corp.
40 Ag. Konstantinou Avenue
Maroussi 15124, Athens, Greece

      Re:	Star Bulk Carriers Corp.
      Amendment No. 2 to Registration Statement on Form F-4
      Filed July 19, 2007
		File No. 333-141296

		Star Maritime Acquisition Corp.
		Amendment No 2 to Preliminary Proxy Statement on Form
PRER
14A
		Filed July 19, 2007
		File No. 1-32685

Dear Mr. Tsirigakis:

      We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your documents in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

General
1. We note your response to comment three in our letter dated June
27, 2007.  Please revise the calculation of the registration fee
table and where appropriate to clarify that the registration
statement, as it concerns shares issued or issuable to the owners
of
vessels to be acquired, covers the resales and not the original
issuance, of such shares.  We reissue the comment.

Recommendations of the Board of Directors
2. We note your response to prior comment 25 and the analyses
provided to the CEO and CFO, who later communicated to the board
the
bases of the financial advisors` evaluations.  As these
evaluations
were provided to management and communicated to the board in
connection with their analyses of the proposed transaction, we
reissue prior comment 25.  Please revise accordingly.

Information Concerning Star Bulk Carriers Corp., page 84

Employment and Consulting Agreements, page 93
3. We note your response to comment 11 in our letter dated June
27,
2007.  Please confirm that your disclosure in this section covers
all
benefits in kind granted to members of your management, including
any
contingent or deferred compensation accrued for the past year even
if
the compensation is payable at a later date.  In addition,
disclose
the total amounts, if any, set aside or accrued by the company or
its
subsidiaries to provide pension, retirement, or similar benefits.

Star Bulk`s Forecasted Cash Available for Dividends Reserves and
Extraordinary Expenses, page 127
4. Per share measures of liquidity are not acceptable in documents
filed with the Commission, accordingly, we reiterate prior comment
34
and refer you to Question 11 of Frequently Asked Questions
Regarding
the Use of Non-GAAP Financial Measures, which is available on our
website at
http://www.sec.gov/divisions/corpfin/faqs/nongaapfaq.htm.
Please revise to delete the per share measure.

Related Party Transactions, page 130
5. We note your response to comment 37 in our letter dated June
27,
2007.  Please clarify whether the company policies and procedures
related to review, approval, or ratification of transactions with
related persons are in writing and, if not, how such polices and
procedures are evidenced.  In addition, explain how the company
will
determine "independence" of the members of the board.
6. Also, please revise your heading and disclosure to address all
related person transactions.  We note the disclosure on page F-28.

Tax Considerations, page 151
7. We reissue comments 105 and 106 from our letter dated April 15,
2007.  Please revise to clearly indicate the statements that
constitute the opinion of Seward & Kissel.  Currently the
statement
on page 31 that the IRS Code provides certain tax treatment
"unless"
certain circumstances occur, does not express an opinion.
Similarly,
the statement on page 155 that Star Bulk will qualify for certain
tax
treatment "provided" certain circumstances exist does not express
an
opinion.  And the statement that actions "will generally
constitute
dividends, which may be taxable" does not provide an opinion.
Also
see "generally be treated" in the last paragraph on page 155.
8. In this regard, please revise the risk factors and here to
clearly
indicate, if true, that Seward & Kissel is not giving an opinion
that
Star Bulk satisfies an exemption for, or is otherwise not subject
to,
treatment as a PFIC.  As such, your tax discussion should clearly
summarize up front the tax consequences of Star Bulk being treated
as
a PFIC.  As the company is not qualified to render an opinion
regarding these tax matters, please revise pages 156 and 157 to
avoid
disclosure suggesting tax consequences that the company believes
are
based on, for example, "substantial legal authority."

Selling Shareholder, page 161
9. Please identify the natural persons who exercise the voting,
investment, and dispositive control over the stock held or to be
held
of record by TMT Co., Ltd.  Also, provide the business address of
the
company.
Form of Proxy
10. We note your response to comment 20 in our letter dated June
27,
2007.  Please revise the proxy statement/prospectus and the form
of
proxy to clarify that shareholders need to approve any adjournment
or
postponement of the special meeting for the purpose of
solicitation
of additional proxies by the company.
Financial Statements of Acquired Vessels
11. We do not agree with your conclusion that the acquisition of
the
eight vessels is an acquisition of assets.  We believe that the
continuation of the existing charters as procured by TMT
constitutes
sufficient continuity of operations so that disclosure of prior
financial information would be material to an understanding of
future
operations. In lieu of full financial statements for the vessels,
we
would not object to the inclusion of an audited statement of
revenues
and direct expenses for the most recent fiscal year only and an
unaudited statement of revenues and direct expenses for the most
recent interim period.  To the extent that the vessels were under
common management or common control during the period for which
financial statements are required, we would not object to the
statements being presented on a combined basis.
12. You are required to provide a pro forma balance sheet and a
pro
forma statement of operations that reflect your acquisition of the
vessels.  We will waive the requirement to provide a pro forma
statement of operations if the use of forward-looking information
is
necessary to meaningfully present the effects of the acquisition.
If
you provide a pro forma statement of operations, limit it to
information that is reliably determinable and do not include
forward-
looking information.  Also disclose how the pro forma statement of
operations is not indicative of your operations going forward
because
it necessarily excludes various operating expenses.  We encourage
you
to include forward-looking information regarding the revenues and
expenses of the vessels, as reorganized under you corporate
structure
and management.  If furnished, clearly identify it as forward-
looking
rather than pro forma.  If the forward-looking information
provided
is not in the form of a comprehensive forecast of revenue and net
earnings, disclose how revenue and operating efficiencies may vary
given the assumptions underlying the forward-looking information
that
you do provide.

* * * * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      You may contact Maureen Bauer, Staff Accountant, at (202)
551-
3237 or Tia Jenkins, Senior Assistant Chief Accountant, at (202)
551-
3871 if you have questions regarding comments on the financial
statements and related matters.  Please contact Pradip Bhaumik,
Attorney-Advisor, at (202) 551-3333 or James Lopez at (202) 551-
3536
with any other questions.

      					Sincerely,



      					John Reynolds
      					Assistant Director

cc.	Gary J. Wolfe, Esq.
      Seward & Kissel LLP
	Fax:  (212) 480-8421

Prokopios (Akis) Tsirigakis
Star Bulk Carriers Corp.
August 15, 2007
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