SecProbe.io

March 26 , 2015

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

Re: GrafTech International Ltd.
Preliminary Proxy Statement on Schedule 14A
Filed March 17 , 2015  by Nathan Milikowsky , et al.
File No.  001-13888

Dear Mr. Feirstein :

We have reviewed the above -referenced  filing and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

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 comments apply 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 these comments, we may have additional comments.

General

1. It appears you  intend to rely on Rule 14a -5(c) to fulfill certain disclosure obligatio ns by
reference to the company’s  proxy statement.  Pleas e note that in our view, reliance on
Rule 14a -5(c) before the company distributes information to security holders is not
appropriate.  Please tell us whether you intend to disseminate your proxy statement prior
to the distribution of the company proxy stat ement and, if so, confirm your understanding
that you must undertake to provide any omitted information to security holders in the
form of a proxy supplement.

2. In light of the requirement under Item 5(b)(1)(iii) of Schedule 14A to state whether or not
any of the participants have been the subject of a criminal conviction  within the last ten
years , please  provide us with a written reply on behalf of each participa nt in response to

Mr. David B. Feirstein
Kirkland & Ellis LLP
March 26, 2015
Page 2
 this line item notwithstanding the fact that a negative response need not be disclosed in
the proxy statement filed on Schedule 14A.

3. Please advise us why NM GTI Investments LLC has not been named as a participant in
the solicitation gi ven that it is a party to the Prospective Nominee Agreement.  Refer to
Instruction 3 to Item 4 of Schedule 14A.

Important Notice Regarding the Availability of Proxy Materials , page 17

4. Please advise us, with a view toward revised disclosure, the method by  which the proxy
statement will be disseminated to record and beneficial owners.  Specifically address
whether or not the disclosure in this section is intended to communicate that Save
GrafTech  is attempting to rely upon Rule 14a -16 for purposes of electr onically
disseminating its proxy statement.

Interests of the Nominees, page 21

5. Please revise to briefly summarize the material terms of the promissory notes from the
company that are held by each participant.  See Item 5(b)(1)(viii) of Schedule 14A.   In
that regard, we note that incorporation by reference is not specifically permitted in Item 5
of Schedule 14.  Refer to Note D to Schedule 14A.

6. We note the disclosure  on page 23  regarding a registration rights and stockholders’
agreement to which cert ain participants are a party.  Please revise to summarize the
material terms of such agreement.  See Item 5(b)(1)(viii) of Schedule 14A.

Solicitation of Proxies, page 24

7. We note your retention of D.F. King & Co., Inc. for solicitation and advisory serv ices.
Please state the cost or anticipate d cost of such services.  See Item 4(b)(3)(ii) of Schedule
14A.

8. Please state the total amount estimated to be spent and the total expenditures to date for,
in furtherance of, or in connection with the solicitation of security holders .  See Item
4(b)(4) of Schedule 14A.

We urge all persons who are responsible for th e 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 relat ing to their disclosure, they are responsible for the accuracy and adequacy of t he
disclosures they have made.

Mr. David B. Feirstein
Kirkland & Ellis LLP
March 26, 2015
Page 3
 In responding to our comments, please provide a written statement from each filing
person acknowledging that:

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

 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 Christina Chalk, Senior Special Counsel, at (202)
551-3263 if you have a ny questions regarding our comments .

Sincerely,

/s/ Tiffany Piland Posil

Tiffany Piland Posil
Special Counsel
Office of Mergers and Acquisitions