SEC Company Response from GRAHAM (GHM) — May 7, 2026
GRAHAM CORP
Date: May 7, 2026 · CIK: 0000716314 · Accession: 0001193125-26-211676
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File numbers found in text: 333-295458
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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