SecProbe.io

CORRESP
1
filename1.htm

corresp

[Letterhead of ACCO World Corporation]

July 15, 2005

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    ACCO World Corporation

Registration Statement on Form S-4

File No. 333-124946

Ladies and Gentlemen:

     Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933,
as amended (the “Securities Act”), ACCO World Corporation (to be renamed ACCO Brands
Corporation, the “Company”) hereby respectfully requests acceleration of the effectiveness of
the above-referenced Registration Statement on Form S-4 (File No. 333-124946), as amended on
June 22, 2005 by Amendment No. 1 thereto and as further amended on July 15, 2005 by Amendment
No. 2 thereto (such Registration Statement, as amended, the “Registration Statement”), relating
to shares of Common Stock, par value $.01 per share (including the associated preferred share
purchase rights), of the Company so that the Registration Statement shall become effective at
5:30 p.m. Eastern time on July 15, 2005.

     The Company is aware of its responsibilities under the Securities Act and the Securities
Exchange Act of 1934, as amended, as they relate to the proposed offering of the securities
specified in the Registration Statement. The Company has not engaged any underwriter, dealer or
agent in connection with the distribution of any of the securities to which the Registration
Statement relates. The Company also acknowledges that:

    •

    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, such action does not foreclose the Commission
from taking any action with respect to the Registration Statement;

    •

    the action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the
disclosure in the Registration Statement; and

    •

    the Company may not assert the action of the Commission or the Staff, acting
pursuant to delegated authority, in declaring the Registration Statement effective
as defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

    Securities and Exchange Commission

    -2-

    July 15, 2005

    Very truly yours,

ACCO WORLD CORPORATION

    By:
    /s/ Mark A. Roche

    Name:
    Mark A. Roche

    Title:
    Secretary

VIA EDGAR AND FACSIMILE