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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

Date
March 21, 2005
Author
Not clearly detected
Form
CORRESP
Company
RPM INTERNATIONAL INC/DE/ (RPM) (CIK 0000110621)

Letter

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

<PAGE>

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.

Show Raw Text
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<FILENAME>filename1.txt
<TEXT>
<PAGE>

                                [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

<PAGE>

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

</TEXT>
</DOCUMENT>