United States securities and exchange commission logo

                             January 29, 2021

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

                                                        Re: Navios Maritime
Partners L.P.
Statement on Form F-4
                                                            Filed January 15,
                                                            File No. 333-252139

       Dear Mr. Frangou:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-4 filed November 15, 2021

       Questions and Answers About the Merger and the Special Meeting
       What are the material U.S. federal income tax consequences of the Merger
to holders of Navios
       Containers Public Units? , page 6

   1.                                                   Please file an opinion
as to the material tax consequences of the Merger. See Item
                                                        601(b)(8) of Regulation
S-K. For guidance, refer to Section III of Staff Legal Bulletin No.
       Opinion of Financial Advisor to the Navios Containers Conflicts
Committee, page 55

   2.                                                   We note your disclosure
that Pareto Securities SA delivered its opinion to the Navios
                                                        Containers Conflicts
Committee to the effect that the Exchange Ratio was fair, from a
                                                        financial point of
view, to the holders of the Navios Containers Public Units. For each
 Angeliki Frangou
Navios Maritime Partners L.P.
January 29, 2021
Page 2
      valuation analysis performed by Pareto to render the fairness opinion,
please disclose the
      valuation or valuation range yielded as a result of such analysis.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration

      Please contact Laura Nicholson, Special Counsel, at (202) 551-3584 or
Loan Lauren
Nguyen, Legal Branch Chief, at (202) 551-3642 with any questions.

FirstName LastNameAngeliki Frangou
                                                           Division of
Corporation Finance
Comapany NameNavios Maritime Partners L.P.
                                                           Office of Energy &
January 29, 2021 Page 2
cc:       Philip Richter
FirstName LastName