SEC Company Response from GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Apr 2, 2018
GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: April 2, 2018 · CIK: 0000931148 · Accession: 0001104659-18-021601
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File numbers found in text: 333-223791
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CORRESP 1 filename1.htm GrafTech International Ltd. 982 Keynote Circle Brooklyn Heights, Ohio USA 44131 April 2, 2018 BY EDGAR AND BY HAND 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. 2 to Registration Statement on Form S-1 Filed on April 2, 2018 File No. 333-223791 Dear Ms. Ravitz: GrafTech International Ltd. (the “Company”) has filed today amendment no. 2 (“Amendment No. 2”) to the registration statement on Form S-1 (File No. 333-223791) (the “Registration Statement”) filed with the Securities and Exchange Commission (the “Commission”) on March 20, 2018. For the convenience of the staff of the Division of Corporation Finance of the Commission, we are also sending, by hand, five copies of Amendment No. 2 in paper format, marked to show changes from amendment no. 1 to the Registration Statement as filed on March 23, 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