SEC Company Response from GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Mar 23, 2018
GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: March 23, 2018 · CIK: 0000931148 · Accession: 0001104659-18-019922
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-223791
Letter
BY EDGAR Amanda Ravitz Assistant Director Office of Electronics and Machinery Division of Corporation Finance Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549
Re: GrafTech International Ltd. Amendment No. 1 to Registration Statement on Form S-1 Filed on March 23, 2018 File No. 333-223791
Dear Ms. Ravitz:
GrafTech International Ltd. (the “Company”) has filed today amendment no. 1 (“Amendment No. 1”) to the registration statement on Form S-1 (File No. 333-223791) filed with the Securities and Exchange Commission (the “Commission”) on March 20, 2018.
As discussed with the staff of the Division of Corporation Finance (the “Staff”) of the Commission, for the convenience of the Staff, we are also sending, by hand, five copies of Amendment No. 1 in paper format, marked to show changes from the third draft registration statement on Form S-1 as confidentially submitted on March 6, 2018.
If the Staff has any questions or requires any additional information, please contact Sandra L. Flow or Alejandro Canelas Fernandez at Cleary Gottlieb Steen & Hamilton LLP at (212)-225-2000.
Very truly yours,
/s/ Quinn J. Coburn
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CORRESP 1 filename1.htm GrafTech International Ltd. 982 Keynote Circle Brooklyn Heights, Ohio USA 44131 March 23, 2018 BY EDGAR Amanda Ravitz Assistant Director Office of Electronics and Machinery Division of Corporation Finance Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: GrafTech International Ltd. Amendment No. 1 to Registration Statement on Form S-1 Filed on March 23, 2018 File No. 333-223791 Dear Ms. Ravitz: GrafTech International Ltd. (the “Company”) has filed today amendment no. 1 (“Amendment No. 1”) to the registration statement on Form S-1 (File No. 333-223791) filed with the Securities and Exchange Commission (the “Commission”) on March 20, 2018. As discussed with the staff of the Division of Corporation Finance (the “Staff”) of the Commission, for the convenience of the Staff, we are also sending, by hand, five copies of Amendment No. 1 in paper format, marked to show changes from the third draft registration statement on Form S-1 as confidentially submitted on March 6, 2018. If the Staff has any questions or requires any additional information, please contact Sandra L. Flow or Alejandro Canelas Fernandez at Cleary Gottlieb Steen & Hamilton LLP at (212)-225-2000. Very truly yours, /s/ Quinn J. Coburn Quinn J. Coburn Vice President, Chief Financial Officer and Treasurer cc: Tom Jones Kristen Lochhead Brian Cascio Securities and Exchange Commission Sandra L. Flow Adam Fleisher Alejandro Canelas Fernandez Cleary Gottlieb Steen & Hamilton LLP