SEC Comment Letter for GRAHAM CORP (GHM) (CIK 0000716314) (GHM) — Oct 4, 2012

GRAHAM CORP (GHM) (CIK 0000716314)
Date: Oct. 4, 2012 · CIK: 0000716314 · Accession: 0000000000-12-055100

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File numbers found in text: 001-08462

Date

March 31, 2012

Author

/s/Brian Cascio

Form

UPLOAD

Company

GRAHAM CORP (GHM) (CIK 0000716314)

Letter

October 4 , 2012 Via E -Mail Mr. Jeffrey F. Glajch Vice President of Finance and Administration and Chief Financial Officer Graham Corporation 20 Florence Avenue Batavia, New York 14020

Re: Graham Corporation Form 10 -K for the Year Ended March 31, 2012 Filed June 7, 2012 File No. 001-08462

Dear Mr. Glajch :

We have completed our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicabl e rules require.

Sincerely,
/s/Brian Cascio

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October 4 , 2012

Via E -Mail
Mr. Jeffrey F. Glajch
Vice President of Finance and Administration
    and Chief Financial Officer
Graham Corporation
20 Florence Avenue
Batavia, New  York 14020

 Re: Graham Corporation
Form 10 -K for the Year Ended March 31, 2012
Filed June 7, 2012
File No.  001-08462

Dear Mr. Glajch :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure  in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicabl e rules require.

Sincerely,

 /s/Brian Cascio

Brian Cascio
Accounting Branch Chief

SecProbe.io