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SEC Comment Letter for GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Jul 25, 2024

GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: July 25, 2024 · CIK: 0000931148 · Accession: 0000000000-24-008464

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File numbers found in text: 001-13888

Date
July 25, 2024
Author
Catherine Hedoux-Delgado
Form
UPLOAD
Company
GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)

Letter

July 25, 2024 Catherine Hedoux-Delgado Interim Chief Financial Officer and Treasurer Graftech International Ltd. 982 Keynote Circle Brooklyn Heights, Ohio 44131 Re:Graftech International Ltd. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-13888 Dear Catherine Hedoux-Delgado: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Manufacturing

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July 25, 2024
Catherine Hedoux-Delgado
Interim Chief Financial Officer and Treasurer
Graftech International Ltd.
982 Keynote Circle
Brooklyn Heights, Ohio 44131
Re:Graftech International Ltd.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-13888
Dear Catherine Hedoux-Delgado:
            We have completed our review of your filing. 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.
Sincerely,
Division of Corporation Finance
Office of Manufacturing