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SEC Company Response from GRAFTECH INTERNATIONAL (EAF) — May 22, 2026

GRAFTECH INTERNATIONAL LTD
Date: May 22, 2026 · CIK: 0000931148 · Accession: 0001193125-26-237005

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File numbers found in text: 333-296171

Date
May 22, 2026
Author
Andrew J. Renacci
Form
CORRESP
Company
GRAFTECH INTERNATIONAL LTD

Letter

Re: GrafTech International Ltd. Registration Statement on Form S-3 (File No. 333-296171) Ladies and Gentlemen: On behalf of GrafTech International Ltd. (the “Company”), the undersigned hereby requests, pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, that the effective time of the Registration Statement on Form S-3 (File No. 333-296171) of the Company be accelerated to 4:30 p.m. Eastern Time on May 27, 2026, or as soon as practicable thereafter. The Company respectfully requests that you notify Kimberly J. Pustulka of such effectiveness by a telephone call to (216) 586-7002. Please contact Kimberly J. Pustulka at Jones Day at (216) 586-7002 if you have any questions concerning this matter. Thank you for your continued attention to this matter.

GrafTech International Ltd. 982 Keynote Circle Brooklyn Heights, Ohio 44131 May 22, 2026 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Attn: Eranga Dias

Very truly yours,
GRAFTECH INTERNATIONAL LTD.

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CORRESP
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 CORRESP

 GrafTech International Ltd.
 982 Keynote Circle Brooklyn
Heights, Ohio 44131 May 22, 2026
 VIA EDGAR United States Securities and Exchange
Commission Division of Corporation Finance 100 F Street, NE
 Washington, D.C. 20549 Attn: Eranga Dias

 Re:
 GrafTech International Ltd.
 Registration Statement on Form S-3 (File
No. 333-296171) Ladies and Gentlemen:
 On behalf of GrafTech International Ltd. (the “Company”), the undersigned hereby requests, pursuant to Rule 461 of Regulation
C promulgated under the Securities Act of 1933, that the effective time of the Registration Statement on Form S-3 (File No. 333-296171) of the Company be
accelerated to 4:30 p.m. Eastern Time on May 27, 2026, or as soon as practicable thereafter. The Company respectfully requests that you notify Kimberly J. Pustulka of such effectiveness by a telephone call to
 (216) 586-7002. Please contact Kimberly J. Pustulka at Jones Day at (216) 586-7002 if you have any questions concerning this matter. Thank you for your continued attention to this matter.

 Very truly yours,

 GRAFTECH INTERNATIONAL LTD.

 By:

 /s/ Andrew J. Renacci

 Name: Andrew J. Renacci

 Title:  Chief Legal Officer and Corporate Secretary

 cc:
 Kimberly J. Pustulka, Esq.