August 9, 2019

Angeliki Frangou
Chairman and Chief Executive Officer
Navios Maritime Acquisition Corporation
Navios Maritime Partners, L.P.
Navios Maritime Holdings, Inc.
7 Avenue de Grande Bretagne, Office 11B2
Monte Carlo, MC 98000 Monaco

       Re: Navios Maritime Acquisition Corporation
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Response dated July 22, 2019 and File No. 001-34104
           Navios Maritime Partners L.P.
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Response dated July 22, 2019 and File No. 001-33811
           Navios Maritime Holdings Inc.
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Response dated July 22, 2019 and File No. 001-33311

Dear Ms. Frangou:

       We have reviewed your July 22, 2019 response to our comment letter and
have the
following 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
July 10, 2019 letter.

Navios Holdings - Form 20-F for the Fiscal Year Ended December 31, 2018

Item 3. Key Information
D. Risk Factors
Risk Relating to Argentina, page 45
 Angeliki Frangou
Navios Maritime Acquisition Corporation
August 9, 2019
Page 2
1.       We have reviewed your response to our prior comment 3 concerning
Navios Holdings. In
         future filings, please expand your Risk Factors section to disclose
that Argentina was
         determined to be a highly inflationary economy as of June 30, 2018,
the economic factors
         resulting in the Argentine economy being highly inflationary, and the
relevant portions of
         your response as to why there was no material impact on your
operations or the need for
         remeasurement of the financial statements of the Argentinian
subsidiary, including the
         fact that the functional currency of the Argentinian subsidiary is the
U.S. dollar and its
         day-to-day operations are dependent on the economic environment of the
parent
         company's U.S. dollar currency.


        You may contact Beverly Singleton at (202) 551-3328 or Claire Erlanger
at (202) 551-
3301 if you have questions regarding comments on the financial statements and
related
matters. Please contact Melissa Raminpour at (202) 551-3379 with any other
questions.



FirstName LastNameAngeliki Frangou                   Sincerely,
Comapany NameNavios Maritime Acquisition Corporation
                                                     Division of Corporation
Finance
August 9, 2019 Page 2                                Office of Transportation
and Leisure
FirstName LastName