SEC Company Response from GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148) (EAF) — Mar 4, 2019
GRAFTECH INTERNATIONAL LTD (EAF) (CIK 0000931148)
Date: March 4, 2019 · CIK: 0000931148 · Accession: 0001104659-19-012543
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-230056
Letter
VIA EDGAR Tim Buchmiller 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. 333-230056)
Dear Mr. Buchmiller:
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 4:40 p.m., Eastern Time, on March 6, 2019 (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/ Gina K. Gunning
Show Raw Text
CORRESP 1 filename1.htm GrafTech International Ltd. 982 Keynote Circle Brooklyn Heights, Ohio USA 44131 March 4, 2019 VIA EDGAR Tim Buchmiller 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. 333-230056) Dear Mr. Buchmiller: 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 4:40 p.m., Eastern Time, on March 6, 2019 (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/ Gina K. Gunning Gina K. Gunning Chief Legal Officer and Corporate Secretary cc: Sandra L. Flow Cleary Gottlieb Steen & Hamilton LLP