SEC Comment Letter for GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Jun 27, 2013

GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: June 27, 2013 · CIK: 0000931148 · Accession: 0000000000-13-035108

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

File numbers found in text: 001-13888

Date

December 31, 2012

Author

/s/ Brian Cascio

Form

UPLOAD

Company

GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)

Letter

June 2 6, 2013 Via E -mail Lindon G. Robertson Vice President and Chief Financial Officer GrafTech International Ltd. 12900 Snow Road Parma, OH 44130

Re: GrafTech In ternational Ltd. Form 10-K for the Fiscal Year Ended December 31, 2012 Filed February 26 , 2013 File No. 001-13888

Dear Mr. R obertson :

We have completed our review of your filings . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the Unite d States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Brian Cascio

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June 2 6, 2013

Via E -mail
Lindon G. Robertson
Vice President and Chief Financial Officer
GrafTech International Ltd.
12900 Snow Road
Parma, OH 44130

 Re: GrafTech In ternational  Ltd.
Form 10-K for the Fiscal Year Ended December 31, 2012
  Filed February 26 , 2013
File No. 001-13888

Dear Mr. R obertson :

We have completed our review of your filings .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the Unite d States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include  the
information the Securities Exchange Act of 1934 and all applicable rules require.

        Sincerely,

        /s/ Brian Cascio

        Brian Cascio
        Accounting Branch Chief

SecProbe.io