Mail Stop 3561



							November 2, 2005




George D. Gourdomichalis, President
FreeSeas, Inc.
93 Akti Miaouli
Piraeus, Greece
011-30-210-4528-770

		RE:	FreeSeas, Inc.
      Registration Statement on Form F-1
			Amendment Filed: October 11, 2005
			File No. 333-124825

Dear Mr. Gourdomichalis:

      We have reviewed your amended filing and have the following
comments.  Where indicated, we think you should revise your
document
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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General
1. Your disclosure regarding the listing of your securities is
confusing because you disclose that Freeseas`s common stock is not
listed on any national stock exchange and you intend to apply for
a
listing on the NASDAQ SmallCap Market.  Yet, Trinity`s securities
are
quoted on the OTC Bulletin Board and a market therefore exists as
it
pertains to the company`s securities.  Revise to clearly indicate
that your securities are/will be quoted on the Bulletin Board and
that, although you intend to seek a listing on the NASDAQ SmallCap
Market, there is no assurance that a listing will be obtained.
2. We note that one of the enumerated conditions in order for
Trinity
to be able to consummate the Merger includes the requirement that
"no
more than 2% of all outstanding shares of Trinity common stock and
Trinity Class B common stock, collectively, exercise their
statutory
appraisal rights."  However, based upon our understanding of
Section
262 of the DGCL, the actual "exercise" of appraisal rights under
the
DGCL does not occur until after the judicial appraisal process has
taken place which by necessity occurs after the consummation of
the
Merger, thus making such exercise inappropriate as a condition to
the
consummation of the Merger.  We do note, however, that under
Section
262 of the DGCL, a notice of intent to seek appraisal rights must
be
provided to the company by any shareholder intending or
considering
an exercise his/her appraisal rights prior to the consummation of
the
Merger.  To the extent that this is the event which is intended to
be
a condition to Trinity being able to consummate the Merger, please
revise your disclosure as necessary.  Alternatively, please
describe
to us how an event which occurs after the consummation of the
Merger
can be a condition precedent to Trinity`s ability to consummate
the
Merger.

Cover Page
3. Limit the outside front cover page to one page as required by
Item
501(a) of Regulation S-K.

Selected Unaudited Pro Forma Financial Information, page 12
4. We note your response to prior comment 20.  Please revise your
disclosure to incorporate the dilutive effect on net income per
share
that will result from the issuance of the shares in the
transaction.
Consider providing a tabular presentation of the shares used in
the
calculation.  Refer to Regulation S-X 11-02(b)(7) and revise your
disclosures accordingly.

Selling Shareholders, page 107
5. Please explain the discrepancies in the number of shares
beneficially owned by Messrs. Varouxakis, G. Gourdomichalis, and
E.
Gourdomichalis as reflected in the beneficial ownership table on
75
and the selling shareholder table on page 107.




   Closing Comments

      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 supplemental 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.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Carlton Tartar at (202) 551-3387 if you have
questions regarding comments on the financial statements and
related
matters.  Questions on other disclosure issues may be directed to
Jay
Ingram at (202) 551-3397, or to Mike Karney, who supervised the
review of your filing, at (202) 551-3847.


      Sincerely,



John Reynolds
Assistant Director
Office of Emerging Growth Companies


cc. 	Jeffry Robinson,. Esq.
	305-995-6402 by facsimile








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George D. Gourdomichalis
FreeSeas, Inc.
November 2, 2005
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