SEC Company Response from GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Apr 13, 2018
GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: April 13, 2018 · CIK: 0000931148 · Accession: 0001104659-18-023826
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-223791
Letter
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. 4 to Registration Statement on Form S-1 Filed on April 13, 2018 File No. 333-223791
Dear Ms. Ravitz:
GrafTech International Ltd. (the “Company”) has filed today amendment no. 4 (“Amendment No. 4”) 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. Amendment No. 4 has been filed solely for the purposes of (i) reflecting the stock split of the Company’s outstanding common stock that was effected on April 12, 2018, and accordingly including the final audit report of the Company’s independent auditors in the prospectus contained in the Registration Statement, (ii) filing certain exhibits to the Registration Statement, including a revised validity opinion (Exhibit 5.1) and (iii) updating certain information in Part II of the Registration Statement.
For the convenience of the staff of the Division of Corporation Finance of the Commission (the “Staff”), we are also sending, by hand, five copies of each of this letter and Amendment No. 4 in paper format, marked to show changes from amendment no. 3 to the Registration Statement as filed on April 4, 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
Show Raw Text
CORRESP 1 filename1.htm GrafTech International Ltd. 982 Keynote Circle Brooklyn Heights, Ohio USA 44131 April 13, 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. 4 to Registration Statement on Form S-1 Filed on April 13, 2018 File No. 333-223791 Dear Ms. Ravitz: GrafTech International Ltd. (the “Company”) has filed today amendment no. 4 (“Amendment No. 4”) 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. Amendment No. 4 has been filed solely for the purposes of (i) reflecting the stock split of the Company’s outstanding common stock that was effected on April 12, 2018, and accordingly including the final audit report of the Company’s independent auditors in the prospectus contained in the Registration Statement, (ii) filing certain exhibits to the Registration Statement, including a revised validity opinion (Exhibit 5.1) and (iii) updating certain information in Part II of the Registration Statement. For the convenience of the staff of the Division of Corporation Finance of the Commission (the “Staff”), we are also sending, by hand, five copies of each of this letter and Amendment No. 4 in paper format, marked to show changes from amendment no. 3 to the Registration Statement as filed on April 4, 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