SecProbe.io

January  26, 2015

Via E-mail
Mr. David B. Feirstein
Kirkland & Ellis LLP
601 Lexington Avenue
New York, NY 10022

Re: GrafTech International Ltd .
Solic iting Material on Schedule 14A f iled by Nathan Milikowsky et al.
Filed January 23, 2015
 File No.  001-13888

Dear Mr. Feirstein :

We have reviewed the above -referenced filing and have the following comment .

Please respond  to this letter by amending the  filing, by providing the requested
information, or by advising us when you will provide the requested response.  If  you do not
believe our comment applies to your facts and circumstances or do not believe an amendment is
appropriate, please  tell us why in  your response.

After reviewing any amendment to the filing and the information you provide in response
to this comment , we may have additional comments.

General
1. Please advise us how the filing complies  with Exchange Act Rule 14a -12(a)(1)(i).

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicab le Exchange Act rules require.  Since the filing persons are in possession of
all facts relating to their disclosure, they are responsible for the accuracy and adequacy of t he
disclosures they have made.

In responding to our comment , please provide  a written statement from each filing person
acknowled ging that:

 the filing person  is responsible for the adequacy and accuracy of the disclosure in the
filing;

David B. Feirstein
Kirkland & Ellis LLP
January 26, 2015
Page 2
  staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

 the filing person  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
United States.

Please contact me at (202) 551 -3589 or Christ ina Chalk , Senior Special Counsel, at (202)
551-3263 if you have any questions regarding our comments.

Sincerely,

        /s/ Tiffany Piland Posil

Tiffany Piland Posil
Special Counsel
Office of Mergers and Acquisitions