SEC Company Response from RPM INTERNATIONAL (RPM) — Mar 17, 2005
RPM INTERNATIONAL INC/DE/ (RPM) (CIK 0000110621)
Date: March 17, 2005 · CIK: 0000110621 · Accession: 0000950152-05-002286
AI Filing Summary & Sentiment
File numbers found in text: 333-120536
Letter
March 17, 2005 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Ms. Pamela A. Long Division of Corporate Finance
Re: RPM International Inc. Registration Statement on Form S-4 File No. 333-120536
Dear Ms. Long:
RPM International Inc. (the "Company") hereby requests, pursuant to Rule 461 under the Securities Act of 1933, as amended, that the effective date of the above-referenced Registration Statement be accelerated to 4:30 p.m. on March 21, 2005, or as soon as practicable thereafter.
The Company acknowledges that:
o should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
o the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
o the Company may not 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.
Very truly yours,
RPM International Inc.
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[RPM LETTERHEAD]
March 17, 2005
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Ms. Pamela A. Long
Division of Corporate Finance
Re: RPM International Inc.
Registration Statement on Form S-4
File No. 333-120536
Dear Ms. Long:
RPM International Inc. (the "Company") hereby requests, pursuant to Rule
461 under the Securities Act of 1933, as amended, that the effective date of the
above-referenced Registration Statement be accelerated to 4:30 p.m. on March 21,
2005, or as soon as practicable thereafter.
The Company acknowledges that:
o should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing;
o the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and
o the Company may not 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.
Very truly yours,
RPM International Inc.
/s/ P. Kelly Tompkins
P. Kelly Tompkins
Senior Vice President,
General Counsel and Secretary
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