August 29, 2018

Mark Kempa
Chief Financial Officer
Norwegian Cruise Line Holdings Ltd.
7665 Corporate Center Drive
Miami, FL 33126

       Re: Norwegian Cruise Line Holdings Ltd.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Form 10-Q for the Fiscal Period Ended June 30, 2018
           File Nos. 001-35784

Dear Mr. Kempa:

       We have reviewed your filings 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.

Form 10-K for the Fiscal Year Ended December 31, 2017

Item 7A - Qualitative and Quantitative Disclosures about Market Risk, page 43

1.    We note that you are exposed to the following market risks: interest rate
risk related to
      your debt instruments, foreign currency exchange rate risk related to
your construction
      contracts denominated in euros, and fuel price risk related to your
operations. Please
      revise your future filings to disclose for all market risks the
quantitative information for
      the preceding fiscal year along with the reasons for material changes in
amounts from the
      preceding year. Refer to 305(a)(3) and Instruction 3(F) to Item 305(a) of
Regulation S-K.
 Mark Kempa
Norwegian Cruise Line Holdings Ltd.
August 29, 2018
Page 2
Form 10-Q for the Fiscal Period Ended June 30, 2018

Note 2 - Summary of Significant Accounting Policies
Revenue and Expense Recognition, page 7

2.       You indicate that third party concessionaires manage retail shops, spa
services, art
         auctions and internet services. These contracts entitle you to a fixed
percentage of the
         gross sales. Please revise your disclosure to indicate if you
recognize revenue from these
         contracts on a net basis pursuant to ASC 606-10-50-12(c).
3.       For onboard and other revenue described in paragraph 2 of your
disclosure related to
         "Nature of goods and services", please revise to disclose the timing
of when revenue is
         recognized pursuant to ASC 606-10-50-18 or 19, as applicable.
4.       We note your description of various goods and services related to your
cruise offerings,
         which may include round-trip airfare and pre-cruise hotel packages.
Provide us with your
         analysis regarding how you determined gross reporting for pre-cruise
and post-cruise
         services was appropriate pursuant to ASC 606-10-55-36 through 39.
Please specifically
         address how you considered the definition of control and how you are
directing any third
         party providers. Tell us why revenue for pre-cruise and post-cruise
service revenue is
         recognized over the duration of each cruise versus as travel occurs
prior to or after the
         cruise.
        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.

       You may contact Jim Dunn at 202-551-2734 or Melissa Raminpour at
202-551-3379 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameMark Kempa                                  Sincerely,
Comapany NameNorwegian Cruise Line Holdings Ltd.
                                                              Division of
Corporation Finance
August 29, 2018 Page 2                                        Office of
Transportation and Leisure
FirstName LastName