MINTZ LEVIN Chrysler Center 666 Third Avenue TODD E. MASON | 212 692 6731 | temason@mintz.com New York, NY 10017 212-935-3000 212-983-3115 fax www.mintz.com August 15, 2006 VIA EDGAR - --------- Sara D. Kalin, Branch Chief - Legal Division of Corporation Finance Securities and Exchange Commission 100 F Street Washington, DC 20549 RE: NAVIOS MARITIME HOLDINGS INC. REGISTRATION STATEMENT ON FORM F-1, AS AMENDED EFFECTIVE ON AUGUST 14, 2006 FILE NO. 333-129382 Dear Ms. Kalin: As requested by Daniel Morris, attached to this letter please find PDF files of the marked copies of the seven (7) amendments that were made to the above referenced registration statement prior to its declaration of effectiveness on August 14, 2006. Each PDF contains the sequentially amended filing marked to reflect the changes made from the prior filing. MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C. Sara D. Kalin, Branch Chief - Legal Securities and Exchange Commission August 15, 2006 Page 2 Should you require further information please do not hesitate to contact me. Sincerely, /s/ Todd E. Mason Todd E. Mason cc: Angeliki Frangou, Chief Executive Officer Navios Maritime Holdings Inc. Daniel Morris Securities and Exchange Commission Heather Tress Securities and Exchange Commission