SEC Company Response from GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Aug 6, 2018
GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: Aug. 6, 2018 · CIK: 0000931148 · Accession: 0001104659-18-049832
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File numbers found in text: 333-226609
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CORRESP 1 filename1.htm GrafTech International Ltd. 982 Keynote Circle Brooklyn Heights, Ohio USA 44131 August 6, 2018 VIA EDGAR Caleb French 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. Registration Statement on Form S-1 (File No. 333-226609) Dear Mr. French: Pursuant to Rule 461 under the Securities Act of 1933, as amended, GrafTech International Ltd. (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form S-1, as amended, be accelerated so that it will be declared effective by 4:30 p.m., Eastern Time, on August 8, 2018 (the “Effective Date”), or as soon as possible thereafter. We ask, however, that the Registration Statement not be declared effective until you speak to our counsel on the Effective Date. Please contact Sandra L. Flow of Cleary Gottlieb Steen & Hamilton LLP, counsel to the Company, at (212) 225-2494, prior to declaring the Registration Statement effective on the Effective Date, or if you have any other questions or concerns regarding this matter. [remainder of page intentionally left blank] Very truly yours, /s/ Quinn J. Coburn Quinn J. Coburn Chief Financial Officer, Vice President Finance and Treasurer cc: Gina Gunning Chief Legal Officer and Secretary GrafTech International Ltd. Sandra L. Flow Cleary Gottlieb Steen & Hamilton LLP