July 30, 2018

John Coustas
Chief Executive Officer
Danaos Corp
c/o Danaos Shipping Co. Ltd., Athens Branch
14 Akiti Kondyli
185 45 Piraeus
Greece

       Re: Danaos Corp
           Registration Statement on Form F-1
           Filed July 9, 2018
           File No. 333-226096

Dear Mr. Coustas:

       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.

Form F-1

General

1.     We note that you are registering the resale of a significant percentage
of your issued and
       outstanding shares of common stock. We further note that the shares will
be issued in
       respect of a debt refinancing agreement that the company entered into on
June 19, 2018,
       which will not be consummated until July 31, 2018. As such, it appears
you are
       attempting to register for resale shares that had not yet been issued
when you filed the
       registration statement. Please advise how this was a completed private
placement prior to
 John Coustas
Danaos Corp
July 30, 2018
Page 2
         filing the registration statement. We may have further comment when we
review your
         response. For guidance, please refer to Question 134.01 of the
Securities Act Section of
         the Compliance and Disclosure Interpretations, available on our
website at www.sec.gov.
        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.

        Please contact Julie Griffith at 202-551-3267 or Susan Block at
202-551-3210 with any
questions.

FirstName LastNameJohn Coustas
Comapany NameDanaos Corp
                                                             Division of
Corporation Finance
July 30, 2018 Page 2                                         Office of
Transportation and Leisure
FirstName LastName