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SEC Company Response from GRAHAM (GHM) — May 7, 2026

GRAHAM CORP
Date: May 7, 2026 · CIK: 0000716314 · Accession: 0001193125-26-211676

Offering / Registration Process

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File numbers found in text: 333-295458

Date
May 7, 2026
Author
Graham Corporation
Form
CORRESP
Company
GRAHAM CORP

Letter

Re: Graham Corporation Registration Statement on Form S-3 Filed April 30, 2026 (File No. 333-295458) Ladies and Gentlemen: In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, Graham Corporation, a Delaware corporation, hereby requests that the effectiveness of the registration statement on Form S-3 (File No. 333-295458), initially filed with the U.S. Securities and Exchange Commission on April 30, 2026, be accelerated so that the registration statement becomes effective at 4:00 p.m. Eastern Time on May 11, 2026 or as soon thereafter as practicable. If you have any questions or comments, please contact Alexander McClean of Harter Secrest & Emery at (585) 231-1248.

Graham Corporation 20 Florence Avenue Batavia, New York May 7, 2026 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549

Very truly yours,
Graham Corporation

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CORRESP
 1
 filename1.htm

 CORRESP

 Graham Corporation
 20 Florence Avenue Batavia, New
York May 7, 2026 VIA EDGAR
 U.S. Securities and Exchange Commission Division of Corporation
Finance 100 F Street, N.E. Washington, D.C. 20549

 Re:
 Graham Corporation
 Registration Statement on Form S-3
 Filed April 30, 2026 (File
No. 333-295458) Ladies and Gentlemen:
 In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, Graham Corporation, a Delaware corporation, hereby
requests that the effectiveness of the registration statement on Form S-3 (File No. 333-295458), initially filed with the U.S. Securities and Exchange Commission on
April 30, 2026, be accelerated so that the registration statement becomes effective at 4:00 p.m. Eastern Time on May 11, 2026 or as soon thereafter as practicable.
 If you have any questions or comments, please contact Alexander McClean of Harter Secrest & Emery at (585) 231-1248.

 Very truly yours,

 Graham Corporation

 By:

 /s/ Christopher Thome

 Christopher Thome Vice President –
Finance, Chief Financial Officer and Chief Accounting Officer