October 9, 2007


VIA EDGAR

Cecilia D. Blye, Esq.
Chief, Office of Global Security Risk
United States Securities and Exchange Commission
100 F Street N.E.
Washington, DC  20549-5546

     Re:   Frontline Ltd.
           Form 20-F for the Fiscal Year Ended December 31, 2005
           File No. 1-16601

Dear Ms. Blye:

     By letter dated November 14, 2006, the Staff of the Securities and Exchange
Commission (the "Staff") requested supplemental information relating to the
Company's Annual Report on Form 20-F for the Fiscal Year ended December 31, 2005
(the "Annual Report"). The Company responded to that letter on January 11, 2007.
By letter dated February 2, 2007, the Staff raised two additional comments. The
Company's responses, together with the Staff's comments, are set forth below.

1. We note your response to prior comment one and the statement that your
   vessels have made "approximately 30 calls while on voyage charters to Iran
   during 2005, which would result in aggregate payments to port authorities
   ranging from $2.8 million to $3.3 million." Please expand your response to
   discuss in narrative and quantitative terms the revenues and expenses
   associated with charters with respect to which Frontline knows that its
   vessels call on Iranian ports.

     The Company has previously advised the Staff that it had a total of three
     charters with Iranian companies during 2005 and 2006. All of the Company's
     other operating revenues derive from charters with non-Iranian entities.
     The Company does not consider charters for the carriage of cargoes from
     Iran to constitute a separate segment of its business. In response to the
     Staff's question regarding revenues and expenses associated with charters
     with respect to which Frontline knows that its vessels call on Iranian
     ports, the Company has performed an analysis in order to identify such
     information. Based on this analysis, during 2005, the Company received
     gross revenues of $71.3 million and incurred total voyage related costs of
     $21.5 million from such charters on a voyage charter basis. Of these
     expenses $2.8 million were port charges paid to Iranian port authorities.
     These amounts exclude five port calls made by vessels on time charter for
     which such information is not readily available to the Company. The
     Company's gross revenues and voyages expenses in 2005 were $1,504.5 million
     and $337.2 million, respectively, and the revenues and expenses associated
     with charters where vessels called at Iranian ports therefore represent
     approximately 4.7 percent and 6.4 percent of total operating revenues and
     total voyage expenses, respectively. Port charges paid to Iranian port
     authorities represent approximately 0.8 percent of total voyage expenses
     for 2005.

2. With respect to your payments to Iranian authorities, and payments to the
   Iranian government by charterers in connection with charters involving your
   vessels, please expand your qualitative materiality analysis, including your
   discussion of the potential impact of your activities upon your reputation
   and share value, to address the possible uses of such cash or other payments
   by a country that is identified as a state sponsor of terrorism. Please also
   address the applicability to your Iran-related activities, including any
   direct or indirect payments to the Iranian government, of Section 5(b) of the
   Iran Sanction Act of 1996, as modified by the Iran Freedom Support Act on
   September 30, 2006.

     As a result of its qualitative materiality analysis, the Company has
     concluded that its payments to Iranian authorities and payments to the
     Iranian government by charterers in connection with charters involving the
     Company's vessels are immaterial to its reputation and its share price. In
     this qualitative materiality analysis, in addition to the factors set forth
     in its letter dated January 11, 2007, the Company has taken into
     consideration the payments that the Company has made to Iranian port
     authorities upon the direction of the charterer when a vessel owned by the
     Company has been under voyage charter to an Iranian loadport and payments
     made by time charterers of its vessels to Iranian port authorities when
     those time charterers have directed a vessel owned by the Company to an
     Iranian loadport.

     As to payments that the Company has made to Iranian port authorities when a
     voyage chartered vessel has called at an Iranian loadport, the Company has
     concluded that these are both quantitatively immaterial to its business and
     qualitatively immaterial to its reputation and share price. In addition,
     the Company in reaching this conclusion believes that investors understand
     that in order to meet its obligations under voyage charters for its
     vessels, the Company is required to pay port fees, which is a normal
     commercial arrangement in the shipping industry.

     Insofar as payments made by time charterers of the Company's vessels to
     Iranian authorities are concerned, the Company has also concluded that
     these are qualitatively immaterial to the Company's reputation and share
     price. The Company's considerations have included the following: (i) The
     Company has no knowledge of what its time charterers pay to Iranian
     authorities, (ii) the Company has no control over payments made by its
     charterers to Iranian authorities, (iii) the Company's charterers are not
     subject to U.S. regulations in chartering its vessels and then directing
     those vessels to Iranian ports to load Iranian oil cargoes, and (iv) the
     Company under the terms of those charters has no right to refuse to take
     Iranian oil cargoes. Therefore, the Company does not believe that payments
     by it or its charterers to Iranian entities would have a material
     qualitative effect on its reputation or its share price.

     In respect of the Iran Sanction Act of 1996, as modified by the Iran
     Freedom Support Act on September 30, 2006, the Company concludes that its
     payments to Iranian port authorities for services rendered when the Company
     is directed by its charterers to enter Iranian ports to load oil cargoes
     for such charterers do not constitute an investment in Iran's energy
     sector.

     Please feel free to contact the undersigned or our U.S. counsel, Gary Wolfe
of Seward & Kissel LLP, at (212) 574-1223 with any questions or comments.

                                              Yours sincerely,



                                              By:  /s/ Bjorn Sjaastad
                                                   ------------------
                                                   Bjorn Sjaastad
                                                   CEO, Frontline Management
                                                   AS for Frontline Ltd
cc: James Lopez, Esq.
    Division of Corporation Finance

    Max Webb, Esq.
    Assistant Director
    Division of Corporation Finance

    Gary J. Wolfe, Esq.
    Seward & Kissel LLP






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