United States securities and exchange commission logo
March 1, 2024
Kleanthis Costa Spathias
Director, Sphinx Investment Corp.
GK Investor LLC
c/o Levante Services Limited
Leoforos Evagorou 31, 2nd Floor, Office 21
1066 Nicosia, Cyprus
Re: GK Investor LLC
Genco Shipping &
Trading Limited
DFAN14A Filed
January 10, 2024
Filed By GK
Investor LLC et al.
File No. 001-33393
Dear Kleanthis Costa Spathias:
We have reviewed your
filing and have the following comment.
Please respond to this comment by providing the requested
information or advise us as
soon as possible when you will respond. If you do not believe our
comment applies to your facts
and circumstances, please tell us why in your response.
After reviewing your
response to this comment, we may have additional comments.
DFAN14A Filed January 10, 2024
Certain Information Concerning the Participants
1. In written soliciting
materials used before a proxy statement is furnished, Rule 14a-
12(a)(1)(i) requires
the soliciting party to include a description of each participant s direct
and indirect interests
in the solicitation, or a legend advising where that information can
be found. Such
interests are not limited to the participant s share ownership in the
registrant. See the
last sentence of CDI 132.03 under Proxy Rules and Schedules 14A/14C
Compliance and
Disclosure Interpretations (November 17, 2023). Consider whether Mr.
Economou s ownership
interest in a rival shipping company, DryShips Inc., and Sphinx
Investment Corp.'s
pending offer to acquire all issued and outstanding common shares of
another shipping
company, Performance Shipping Inc., constitute interests in this
solicitation. Please
disclose in future filings, or advise.
Kleanthis Costa Spathias
GK Investor LLC
March 1, 2024
Page 2
We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please direct any questions to Shane Callaghan at 202-551-6977 or
Christina Chalk at
202-551-3263.
FirstName LastNameKleanthis Costa Spathias Sincerely,
Comapany NameGK Investor LLC
Division of
Corporation Finance
March 1, 2024 Page 2 Office of Mergers &
Acquisitions
FirstName LastName