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<SEC-DOCUMENT>0000000000-07-047341.txt : 20071217
<SEC-HEADER>0000000000-07-047341.hdr.sgml : 20071217
<ACCEPTANCE-DATETIME>20070927172648
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-07-047341
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20070927

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			Star Bulk Carriers Corp.
		CENTRAL INDEX KEY:			0001386716
		STANDARD INDUSTRIAL CLASSIFICATION:	DEEP SEA FOREIGN TRANSPORTATION OF FREIGHT [4412]
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			1T
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		40 AG. KONSTANTINOU AVENUE
		STREET 2:		AETHRION CENTER, SUITE B34, MAROUSSI 151
		CITY:			ATHENS
		STATE:			J3
		ZIP:			00000
		BUSINESS PHONE:		011-30-210-638-7399

	MAIL ADDRESS:	
		STREET 1:		40 AG. KONSTANTINOU AVENUE
		STREET 2:		AETHRION CENTER, SUITE B34, MAROUSSI 151
		CITY:			ATHENS
		STATE:			J3
		ZIP:			00000
PUBLIC REFERENCE ACCESSION NUMBER:		0001047469-07-006776
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>


      September 27, 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. 3 to Registration Statement on Form F-4
      Filed August 31, 2007
		File No. 333-141296

		Star Maritime Acquisition Corp.
		Amendment No 3 to Preliminary Proxy Statement on Form
PRER
14A
		Filed August 31, 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. Please revise to eliminate unnecessary repetition.  As a non-
exclusive example, you discuss the conditions to the asset
acquisition on the cover page, pages 1, 3, 11, 12 and elsewhere.
Please revise accordingly.

Questions and Answers, page 1
2. Please revise the second Q&A and where appropriate to disclose
that there are three proposals.
3. Please revise the second sentence of the last paragraph on page
four to clearly indicate that you have received an opinion from
Seward & Kissel that you should not be taxed as a U.S. corporation
under Section 7874(b), explaining the reason for the uncertainty
regarding such opinion.

Summary, page 8
4. Due to the complex structure of the redomiciliation merger,
asset
acquisition, and the equity holdings of the target before and
after
consummation of the transaction, please revise to include a
graphic
presentation illustrating the companies` ownership before and
after
the business combination.

Compensation of Directors and Executive Officers, page 92
5. Please revise to provide the disclosure responsive to Item 402
of
Regulation S-K.  As a non-exclusive example, what specific items
of
corporate performance and other items are taken into account in
determining the "discretionary bonus not less than E 500,000" for
Messrs. Tsirigakis and Syllantavos?  How do the benefits disclosed
in
the first two paragraphs on page 94 and the company`s decisions
regarding each of these benefits fit into the company`s overall
compensation objectives and affect decisions regarding other
elements
of their compensation?

Tax Considerations, page 152
6. You state in the introductory paragraph that "(t)he following
discussion addresses certain U.S. federal income tax
consequences..."
Please delete the word "certain" as it raises a concern that
counsel
may be omitting a material tax consequence.
7. In the second paragraph, you state that certain parts of the
prospectus "accurately sets forth, in all material aspects" the
material U.S. federal tax consequences.  Please revise to delete
"accurately" and state that the specific parts of the prospectus,
which are referred to in that sentence, represent the opinion of
tax
counsel.
8. Please revise the first full paragraph on page 157 to state
that
dividends "would" be treated as qualified dividend income to
emphasize the conditions described in the rest of the paragraph.
Similarly, please revise to state, if true, that you have not
received an opinion of counsel on this issue.

Method of Accounting for the Acquisition of Vessels
9. As a result of a conference call held on September 25, 2007
between Star`s legal counsel and certain accounting staff of the
Division of Corporation Finance, no resolution has yet been
reached
concerning the appropriate method of accounting for the
acquisition
of the vessels.  The staff expects to receive documentation from
Star
as discussed during the call and we will resume our deliberations
at
that time.  We may have further comments on this matter.

Statement of Forecasted Results of Operations and Cash Available
for
Dividends, Reserves and Extraordinary Expenses, page 127
10. It appears that Estimated EBITDA on page 127 should be
$18,170.
Please revise.

Star Maritime Acquisition Corp.
Interim Financial Statements, page F-19
11. Please tell us the reasons that the interim financial
statements
in Star Maritime Acquisition Corp.`s June 30, 2007 Form 10-Q do
not
agree with the financial statements beginning on page F-19 in the
registration statement.  In the event of an error correction, the
disclosures specified in paragraph 26 of SFAS 154 and paragraph 26
of
APB Opinion 9 should be provided in the notes to the financial
statements in the registration statement.
12. Please revise the registration statement or the Form 10-Q so
that
the interim financial statements are identical.

* * * * *

      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.
September 27, 2007
Page 1



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