SEC Company Response from RPM INTERNATIONAL (RPM) — Mar 21, 2005
RPM INTERNATIONAL INC/DE/ (RPM) (CIK 0000110621)
Date: March 21, 2005 · CIK: 0000110621 · Accession: 0000950152-05-002349
AI Filing Summary & Sentiment
File numbers found in text: 333-120536
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[RPM LETTERHEAD]
March 21, 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 23, 2005, or as soon as practicable thereafter. The Company
withdraws its earlier acceleration request filed with the Commission on March
17, 2005.
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
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Ms. Pamela A. Long
Division of Corporate Finance
Securities and Exchange Commission
March 21, 2005
Page 2
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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