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MINTZ LEVIN Chrysler Center 666 Third Avenue KENNETH R. KOCH | 212 692 6768 | kkoch@mintz.com New York, NY 10017 212-935-3000 212-983-3115 fax www.mintz.com July 12, 2006 VIA EDGAR AND FEDEX - ------------------- Sara D. Kalin, Branch Chief - Legal Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549 RE: NAVIOS MARITIME HOLDINGS INC. AMENDMENT NO. 5 TO REGISTRATION STATEMENT ON FORM F-1 FILED ON JULY 12, 2006 FILE NO. 333-129382 Dear Ms. Kalin: On behalf of Navios Maritime Holdings Inc. (the "Company"), we acknowledge, in response to the Staff's verbal confirmation on June 16, 2006, that it had no further comments on the Company's prior filing, Amendment No. 4 to the Registration Statement on Form F-1. As discussed with the Staff, the Amendment No. 5 filing is being filed to: (i) update the opinion of Reeder & Simpson; (ii) update the filing to include the financial statements and operational results and related information, of the first fiscal quarter of the Company ended March 31, 2006; and (iii) update the filing to reflect the recently completed warrant exercise transaction that has resulted in the number of outstanding publicly traded warrants to be reduced from 65,550,000 to 49,571,720. Please note that for the Staff's convenience we have enclosed two (2) courtesy copies of Amendment No. 5 that have been marked to reflect this additional information, and certain other minor changes to update date specific information that has changed from the prior filing. Sincerely, /s/ Kenneth R. Koch Kenneth R. Koch cc: Angeliki Frangou, Chief Executive Officer Navios Maritime Holdings Inc. Daniel Wilson Securities and Exchange Commission Heather Tress Securities and Exchange Commission