SEC Comment Letter for GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Oct 16, 2018

GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: Oct. 16, 2018 · CIK: 0000931148 · Accession: 0000000000-18-032379

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

October 15, 2018

Author

Gina K. Gunning, Esq.

Form

UPLOAD

Company

GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)

Letter

October 15, 2018 Gina K. Gunning, Esq. Chief Legal Officer GrafTech International Ltd. 982 Keynote Circle Brooklyn Heights, OH 44131 Re:GrafTech International Ltd. Draft Registration Statement on Form S-1 Submitted October 12, 2018 CIK No. 0000931148 Dear Ms. Gunning: 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 Tim Buchmiller at (202) 551-3635 with any questions. Sincerely, Division of Corporation Finance Office of Electronics and Machinery cc: Sandra L. Flow, Esq.

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October 15, 2018
Gina K. Gunning, Esq.
Chief Legal Officer
GrafTech International Ltd.
982 Keynote Circle
Brooklyn Heights, OH 44131
Re:GrafTech International Ltd.
Draft Registration Statement on Form S-1
Submitted October 12, 2018
CIK No. 0000931148
Dear Ms. Gunning:
            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 Tim Buchmiller at (202) 551-3635 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       Sandra L. Flow, Esq.

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