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                             September 8, 2022

       Semiramis Paliou
       Director and Chief Executive Officer
       Diana Shipping Inc.
       Pendelis 16
       175 64 Palaio Faliro
       Athens, Greece

                                                        Re: Diana Shipping Inc.
                                                            Registration
Statement on Form F-3
                                                            Filed August 19,
2022
                                                            File No. 333-266999

       Dear Mr. Paliou:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comments. In some of our comments, we may ask you to
provide us with
       information so we may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-3

       Exhibits

   1.                                                   We note your disclosure
that on August 10, 2022, you entered into an agreement with Sea
                                                        Trade Holdings Inc. to
acquire nine dry bulk vessels for an aggregate purchase price of
                                                        $330 million,
consisting of $220 million in cash and an aggregate of 18,487,395 of your
                                                        common shares
underlying warrants that you issued to Sea Trade on August 17, 2022 and
                                                        are exercisable upon
the delivery of the vessels. We also note you disclose this
                                                        registration statement
is being filed to register the resale of the shares underlying these
                                                        warrants pursuant to a
registration rights agreement you also entered into with Sea Trade.
                                                        Please file the
registration rights agreement, or tell us why you believe you are not
                                                        required to do so.
Refer to Item 601(b) of Regulation S-K.
 Semiramis Paliou
Diana Shipping Inc.
September 8, 2022
Page 2

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact contact Irene Barberena-Meissner, Staff Attorney, at
202-551-6548 or
Laura Nicholson, Special Counsel, at 202-551-3584 with any questions.



                                                           Sincerely,
FirstName LastNameSemiramis Paliou
                                                           Division of
Corporation Finance
Comapany NameDiana Shipping Inc.
                                                           Office of Energy &
Transportation
September 8, 2022 Page 2
cc:       Edward S. Horton, Esq.
FirstName LastName