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                                                            December 13, 2024

Aristides Pittas
Chief Executive Officer
Euroholdings Ltd.
4, Messogiou & Evropis Street
Maroussi, 15124
Greece

        Re: Euroholdings Ltd.
            Amendment No. 1 to Draft Registration Statement on Form 20-F
            Submitted November 29, 2024
            CIK No. 0002032779
Dear Aristides Pittas:

     We have reviewed your amended draft registration statement and have the
following
comments.

       Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

      After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form 20-F
Preferred Stock Purchase Rights, page 92

1.      We note your disclosure that you entered into a Stockholders Rights
Agreement with
        American Stock Transfer and Trust Company, LLC, pursuant to which you
will
        declare a dividend payable of one preferred stock purchase right for
each share of
        common stock outstanding "immediately following the consummation of
Diana
        Shipping   s distribution of our common shares." Please clarify Diana
Shipping's role in
        the Spin-Off and/or this agreement, as this entity is not otherwise
referenced in this
        registration statement.
 December 13, 2024
Page 2

Index to unaudited interim condensed combined carve-out financial statements
Notes to the unaudited interim condensed combined carve-out financial
statements
Note 4. Vessels, Net, page F-8

2.     We note that your vessels, net balance was $6,080,200 as of June 30,
2024 and that
       you reported $16,019 and $795,940 of depreciation expense for the six
months ended
       June 30, 2024 and 2023, respectively. You disclose the significant
decline in vessel
       depreciation was due to the fact that the last of the three vessels was
fully depreciated
       in the six-month period ended June 30, 2024. Please clarify the nature
of the amounts
       included in the remaining balance of "vessels, net" and the applicable
depreciation
       policy for each of these components. For example, if amounts relate to
vessel
       improvements, disclose the useful life you have applied and the basis
for your
       determination. Please also provide us with your calculation for
depreciation expense
       recorded for the six months ended June 30, 2024. Lastly, please revise
the title of the
       last line item in the table to state    June 30, 2024.
        Please contact Myra Moosariparambil at 202-551-3796 or Craig Arakawa at
202-551-
3650 if you have questions regarding comments on the financial statements and
related
matters. Please contact Claudia Rios at 202-551-8770 or Irene
Barberena-Meissner at 202-
551-6548 with any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation
cc:   Anthony Tu-Sekine, Esq.
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