MAIDEN
HOLDINGS, LTD.
131 FRONT
STREET, 2ND FLOOR
HAMILTON
HM12 BERMUDA
MAIDEN
HOLDINGS NORTH AMERICA, LTD.
6000
MIDLANTIC DRIVE, SUITE 200S
MOUNT
LAUREL, NEW JERSEY 08054
February
10, 2011
Johnny
Gharib, Esq.
Attorney
Securities
and Exchange Commission
Division
of Corporation Finance
100 F.
Street NE
Washington,
D.C. 20549
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Re:
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Maiden
Holdings, Ltd. (“Maiden”) and
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Maiden
Holdings North America, Ltd. (“Maiden
NA”)
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Registration Statement
on Form S-3 (File Nos. 333-172107 and
333-172107-01)
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Dear
Mr. Gharib:
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Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”),
each of Maiden and Maiden NA hereby requests that the effective date for the
above-referenced Registration Statement be accelerated so that it will be
declared effective under the Securities Act at 4:30 p.m., New York City time, on
Friday, February 11, 2011, or as soon thereafter as reasonably
practicable.
In
connection with this request, each of Maiden and Maiden NA hereby acknowledges
that:
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1.
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should
the Securities and Exchange Commission (the “Commission”) or the staff of
the Commission (the “Staff”), acting pursuant to delegated authority,
declare the Registration Statement effective, it does not foreclose the
Commission from taking any action with respect to the Registration
Statement;
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2.
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the
action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not
relieve either Maiden or Maiden NA from its respective full responsibility
for the adequacy and accuracy of the disclosure in the Registration
Statement; and
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3.
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neither
Maiden nor Maiden NA may assert Staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United
States.
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[Remainder
of the Page Intentionally Left Blank]
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Very
truly yours,
MAIDEN
HOLDINGS, LTD.
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By:
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/s/ Lawrence F. Metz | |
| Name: Lawrence F. Metz | |||
| Title: Senior Vice President, General Counsel and Secretary | |||
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MAIDEN
HOLDINGS NORTH AMERICA, LTD.
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By:
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/s/ Lawrence F. Metz | |
| Name: Lawrence F. Metz | |||
| Title: Secretary | |||