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                                     August 30, 2006


VIA EDGAR
- ---------

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549


         RE:    NAVIOS MARITIME HOLDINGS INC.
                DEL-AM
                File No. 333-136936


Dear Sir or Madam:

         Reference is made to the Registration Statement (the "Registration
Statement") on Form F-3 filed by Navios Maritime Holdings Inc. ("Navios") on
August 28, 2006 (file number 333-136936). On behalf of Navios, the Registration
Statement is hereby amended to include the following:

         "THE REGISTRANT HEREBY AMENDS THIS REGISTRATION STATEMENT ON SUCH DATE
         OR DATES AS MAY BE NECESSARY TO DELAY ITS EFFECTIVE DATE UNTIL THE
         REGISTRANT SHALL FILE A FURTHER AMENDMENT WHICH SPECIFICALLY STATES
         THAT THIS REGISTRATION STATEMENT SHALL THEREAFTER BECOME EFFECTIVE IN
         ACCORDANCE WITH SECTION 8(A) OF THE SECURITIES ACT OF 1933 OR UNTIL THE
         REGISTRATION STATEMENT SHALL BECOME EFFECTIVE ON SUCH DATE AS THE
         COMMISSION, ACTING PURSUANT TO SAID SECTION 8(A), MAY DETERMINE."




                                              Sincerely,


                                              /s/ Kenneth R. Koch


                                              Kenneth R. Koch