[NAVIOS MARITIME HOLDINGS INC LETTERHEAD]
July 23, 2015
Ms. Melissa Raminpour
Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
100 F. Street, N.E.
Washington D.C. 20549
| Re: | Navios Maritime Holdings Inc. |
Form 20-F for the Year Ended December 31, 2014
Filed April 3, 2015
File No. 001-33311
Dear Ms. Raminpour:
Navios Maritime Holdings Inc. (the “Company”) hereby acknowledges that:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in its filings; |
| • | Staff comments or changes to disclosures in response to Staff comments do not foreclose the Commission from taking any action with respect to our filings; and |
| • | the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
| Sincerely, |
| /s/ Vasiliki Papaefthymiou |
| Vasiliki Papaefthymiou |
| Executive Vice President, Legal |
| cc: | Melissa Gilmore, Securities and Exchange Commission |
George Achniotis, Navios Maritime Holdings Inc.
Stuart Gelfond, Fried, Frank, Harris, Shriver & Jacobson LLP
Mark Hayek, Fried, Frank, Harris, Shriver & Jacobson LLP