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SEC Company Response from WESCO INTERNATIONAL INC (WCC) (CIK 0000929008) (WCC) — Jun 2, 2006

WESCO INTERNATIONAL INC (WCC) (CIK 0000929008)
Date: June 2, 2006 · CIK: 0000929008 · Accession: 0000950152-06-004889

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File numbers found in text: 333-133422

Date
June 1, 2006
Author
/s/ Daniel A. Brailer
Form
CORRESP
Company
WESCO INTERNATIONAL INC (WCC) (CIK 0000929008)

Letter

[WESCO letterhead]

June 1, 2006

VIA FACSIMILE: (202) 772-9218

CONFIRMATION COPY VIA FEDERAL EXPRESS

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-3628

Attention:

Jay Mumford

Division of Corporation Finance

Re:

WESCO International, Inc.

WESCO Distribution, Inc.

Registration Statement on Form S-4 (No. 333-133422)

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 9:00 a.m., Eastern Standard Time, on Tuesday, June 6, 2006, 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 Corporate Finance

June 1, 2006

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,
/s/ Daniel A. Brailer,

Show Raw Text
CORRESP
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corresp

[WESCO letterhead]

June 1, 2006

VIA FACSIMILE: (202) 772-9218

CONFIRMATION COPY VIA FEDERAL EXPRESS

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-3628

    Attention:

    Jay Mumford

Division of Corporation Finance

    Re:

    WESCO International, Inc.

WESCO Distribution, Inc.

Registration Statement on Form S-4 (No. 333-133422)

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 9:00 a.m.,
Eastern Standard Time, on Tuesday, June 6, 2006, 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 Corporate Finance

June 1, 2006

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,

    /s/ Daniel A. Brailer,

    on behalf of the Registrants

cc: Michael C. McLean, Esq.