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SEC Company Response from ACCURIDE CORP (CIK 0000817979) — Apr 20, 2005

ACCURIDE CORP (CIK 0000817979)
Date: April 20, 2005 · CIK: 0000817979 · Accession: 0001047469-05-010835

AI Filing Summary & Sentiment

File numbers found in text: 333-121944

Date
April 21, 2005
Author
Assistant Director
Form
CORRESP
Company
ACCURIDE CORP (CIK 0000817979)

Letter

Securities and Exchange Commission Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549 RE:Accuride Corporation Common Stock File No. 333-121944, Form S-1

Dear Sirs:

In connection with the proposed offering of the above-captioned Securities, we wish to advise you that we hereby join with the Registrant's request that the effective date of the above-captioned Registration Statement be accelerated so that the same will become effective on April 21, 2005 at 2:00 p.m. or as soon as practicable thereafter.

Supplemental information supplied under Rule 418(a)(7) under the Securities Act of 1933:

(i)Date of Preliminary Prospectus: April 1, 2005

(ii)Dates of distribution: April 1, 2005—April 7, 2005

(iii)Number of prospective underwriters: 8

(iv)Number of prospectuses distributed under (iii) above: approximately 27,500

(v)Compliance with Rule 15c2-8 under the Securities Exchange Act of 1934: Included in Master Agreement Among Underwriters of Salomon Smith Barney Inc. (now known as Citigroup Global Markets Inc.).

Very truly yours,
Citigroup Global Markets Inc.

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CORRESP
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Accuride Corporation
  7140 Office Circle
  Evansville, Indiana 47715

April 20,
2005

VIA FACSIMILE AND EDGAR TRANSMISSION

Max
A. Webb

Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-0303

Re:Accuride
Corporation

Registration Statement on Form S-1

File No. 333-121944

Ladies
and Gentlemen:

        In
accordance with Rule 461 under the Securities Act of 1933, we hereby request acceleration of the effective date of the Registration Statement on Form S-1
(No. 333-121944) (the "Registration Statement") of Accuride Corporation (the
"Registrant"). We respectfully request that the Registration Statement become effective as of 2:00 p.m., Washington, D.C. time, on
April 21, 2005, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins
LLP, by calling Mark Roeder at
(650) 463-3043. We also respectfully request that a copy of the written order from the Securities and Exchange Commission (the
"Commission") verifying the effective time and date of the Registration Statement be sent to our counsel, Latham & Watkins LLP, Attention: Mark
Roeder, by facsimile to (650) 463-2600.

        The
Company acknowledges the following:

•Should
the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;

•The
action of the Commission or the staff, acting pursuant to delegated authority in declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

•The
Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

        Please
do not hesitate to call Mr. Roeder at (650) 463-3043 if you have any questions regarding this request.

Very truly yours,

/s/ David K. Armstrong

David K. Armstrong

Senior Vice President/General Counsel and

Corporate Secretary

April 20, 2005

Securities
and Exchange Commission

Judiciary Plaza

450 Fifth Street, N.W.

Washington, D.C. 20549

RE:Accuride
Corporation

Common Stock

File No. 333-121944, Form S-1

Dear
Sirs:

        In
connection with the proposed offering of the above-captioned Securities, we wish to advise you that we hereby join with the Registrant's request that the effective date of the
above-captioned Registration Statement be accelerated so that the same will become effective on April 21, 2005 at 2:00 p.m. or as soon as practicable thereafter.

        Supplemental
information supplied under Rule 418(a)(7) under the Securities Act of 1933:

(i)Date
of Preliminary Prospectus: April 1, 2005

(ii)Dates
of distribution: April 1, 2005—April 7, 2005

(iii)Number
of prospective underwriters: 8

(iv)Number
of prospectuses distributed under (iii) above: approximately 27,500

(v)Compliance
with Rule 15c2-8 under the Securities Exchange Act of 1934: Included in Master Agreement Among Underwriters of Salomon Smith
Barney Inc. (now known as Citigroup Global Markets Inc.).

Very truly yours,

Citigroup Global Markets Inc.

/s/  JOHN C. COCCHIARELLA       John C. Cocchiarella

Vice President and Associate General Counsel

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Accuride Corporation 7140 Office Circle Evansville, Indiana 47715