SEC Comment Letter for GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Aug 1, 2018
GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: Aug. 1, 2018 · CIK: 0000931148 · Accession: 0000000000-18-023797
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Letter
August 1, 2018 David J. Rintoul Chief Executive Officer GrafTech International Ltd. 982 Keynote Circle Brooklyn Heights, OH 44131 Re:GrafTech International Ltd. Draft Registration Statement on Form S-1 Submitted July 20, 2018 CIK 0000931148 Dear Mr. Rintoul: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours prior to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Caleb French at 202-551-6947 with any questions. Division of Corporation Finance Office of Electronics and Machinery cc: Sandra L. Flow, Esq.
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August 1, 2018
David J. Rintoul
Chief Executive Officer
GrafTech International Ltd.
982 Keynote Circle
Brooklyn Heights, OH 44131
Re:GrafTech International Ltd.
Draft Registration Statement on Form S-1
Submitted July 20, 2018
CIK 0000931148
Dear Mr. Rintoul:
This is to advise you that we do not intend to review your registration statement.
We request that you publicly file your registration statement no later than 48 hours prior
to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Caleb French at 202-551-6947 with any questions.
Division of Corporation Finance
Office of Electronics and Machinery
cc: Sandra L. Flow, Esq.