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SEC Company Response from WESCO INTERNATIONAL INC (WCC) (CIK 0000929008) (WCC) — Aug 11, 2009

WESCO INTERNATIONAL INC (WCC) (CIK 0000929008)
Date: Aug. 11, 2009 · CIK: 0000929008 · Accession: 0000950123-09-033669

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File numbers found in text: 333-160818

Date
August 11, 2009
Author
/s/ Stephen A. Van Oss
Form
CORRESP
Company
WESCO INTERNATIONAL INC (WCC) (CIK 0000929008)

Letter

FORM CORRESP

August 11, 2009

COPY TO BE SUBMITTED VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-3628

Attention:

Thomas Jones

Division of Corporation Finance

Re:

WESCO International, Inc.

WESCO Distribution, Inc.

Registration Statement on Form S-4 (No. 333-160818)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), WESCO International, Inc. and WESCO Distribution, Inc. (collectively, the “Registrants”) hereby respectfully request that the effective date of the above-referenced Registration Statement be accelerated so that the same will become effective under the Securities Act at 4:30 p.m., Eastern Standard Time, on Wednesday, August 12, 2009, or as soon as practicable thereafter.

Additionally, the Registrants hereby acknowledge the following:

(i)

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;

(ii)

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

Securities and Exchange Commission

Division of Corporation Finance

August 11, 2009

Page 2

(iii)

The Registrants may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
By:
/s/ Stephen A. Van Oss

Show Raw Text
CORRESP
1
filename1.htm

FORM CORRESP

August 11, 2009

COPY
TO BE SUBMITTED VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-3628

    Attention:

    Thomas Jones

    Division of Corporation Finance

    Re:

    WESCO International, Inc.

    WESCO Distribution, Inc.

    Registration Statement on Form S-4 (No. 333-160818)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

     Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities
Act”), WESCO International, Inc. and WESCO Distribution, Inc. (collectively, the “Registrants”)
hereby respectfully request that the effective date of the above-referenced Registration Statement
be accelerated so that the same will become effective under the
Securities Act at 4:30 p.m.,
Eastern Standard Time, on Wednesday, August 12, 2009, or as soon as practicable thereafter.

     Additionally, the Registrants hereby acknowledge the following:

    (i)

    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;

    (ii)

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

Securities and Exchange Commission

Division of Corporation Finance

August 11, 2009

Page 2

    (iii)

    The Registrants may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

    Very truly yours,

    By:
               /s/ Stephen A. Van Oss

    Stephen A. Van Oss

    Senior Vice President and

     Chief Administrative Officer