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SEC Comment Letter for GRAHAM (GHM) — May 6, 2026

GRAHAM CORP
Date: May 6, 2026 · CIK: 0000716314 · Accession: 0000000000-26-004644

Offering / Registration Process

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File numbers found in text: 333-295458

Date
May 6, 2026
Author
Division of
Form
UPLOAD
Company
GRAHAM CORP

Letter

Re: Graham Corporation Registration Statement on Form S-3 Filed April 30, 2026 File No. 333-295458 Dear Christopher Thome:

May 6, 2026

Christopher Thome Chief Financial Officer Graham Corporation 20 Florence Avenue Batavia, New York 14020

This is to advise you that we have not reviewed and will not review your registration statement.

Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Uwem Bassey at 202-551-3433 or Jeff Kauten at 202-551-3447 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Technology
cc: Alexander R. McClean

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 6, 2026

Christopher Thome
Chief Financial Officer
Graham Corporation
20 Florence Avenue
Batavia, New York 14020

 Re: Graham Corporation
 Registration Statement on Form S-3
 Filed April 30, 2026
 File No. 333-295458
Dear Christopher Thome:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Uwem Bassey at 202-551-3433 or Jeff Kauten at
202-551-3447 with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Alexander R. McClean
</TEXT>
</DOCUMENT>