SEC Comment Letter for GRAHAM CORP (GHM) (CIK 0000716314) (GHM) — Sep 30, 2014

GRAHAM CORP (GHM) (CIK 0000716314)
Date: Sept. 30, 2014 · CIK: 0000716314 · Accession: 0000000000-14-049044

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File numbers found in text: 001-8462

Date

September 30, 2014

Author

/s/ Brian Cascio

Form

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Company

GRAHAM CORP (GHM) (CIK 0000716314)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE September 30, 2014 Via E -mail Jeffrey Glajch Chief Financial Officer Graham Corporation 20 Florence Avenue Batavia, New York 14020

Re: Graham Corporation Form 10 -K for the fis cal year ended March 31, 201 4 Filed June 4, 2014 File No. 001-8462

Dear M r. Glajch :

We have completed our review of your filings. 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 filings and the company may not assert staff comments as a defense in any procee ding 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 filings to be certain that the filings include the inform ation the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Brian Cascio

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
       September 30, 2014

Via E -mail

Jeffrey Glajch
Chief Financial  Officer
Graham Corporation
20 Florence Avenue
Batavia, New York  14020

 Re: Graham Corporation
  Form 10 -K for the fis cal year ended March  31, 201 4
  Filed June 4, 2014
  File No. 001-8462

Dear M r. Glajch :

We have completed our review of your filings.  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 filings and the
company may not assert staff comments as a defense in any procee ding 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 filings to be certain that the filings include the inform ation the Securities Exchange
Act of 1934 and all applicable rules require.

Sincerely,

/s/ Brian Cascio

Brian Cascio
Accounting Branch Chief

SecProbe.io