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      Century Aluminum Company Form 10-K for the Fiscal Year Ended December 31, 2006
      Comment Letter

              Curtis,
                Mallet-Prevost, Colt & Mosle llp

              Attorneys
                and Counselors at Law

              101
                Park Avenue

              New
                York, New York 10178-0061

              Frankfurt

              Muscat

              Telephone

              212-696-6000

              Houston

              Paris

              Facsimile

              212-697-1559

              London

              Stamford

              E-Mail

              info@cm-p.com

              Mexico
                City

              Washington,
                D.C.

              Internet

              www.cm-p.com

              Milan

    April
      25,
      2007

    VIA
      EDGAR AND FACSIMILE

    Division
      of Corporation Finance

    U.S.
      Securities and Exchange Commission

    100
      F
      Street, N.E.

    Washington,
      D.C. 20549

    Attention: Mr.
      Karl
      Hiller, Branch Chief

    Re: Century
      Aluminum Company

    Form
      10-K for the Fiscal Year Ended December 31, 2006

    Filed
      March 1, 2007

    File
      No. 0-27918

    Ladies
      and Gentlemen:

    On
      behalf
      of Century Aluminum Company, a Delaware company (the “Company”),
      we
      are providing this letter in response to the comments raised in the letter
      dated
      April 12, 2007 (the “Comment
      Letter”)
      from
      the staff (the “Staff”)
      of the
      Securities and Exchange Commission to Mr. Michael A. Bless, Chief Financial
      Officer of the Company. Set forth below are the Company's responses to the
      Staff's comments. To facilitate your review, each Staff comment, as set forth
      in
      the Comment Letter, is reprinted in italics, numbered to correspond with the
      paragraph numbers assigned in the Comment Letter, and is followed by the
      corresponding response from the Company.

    Form
      10-K for the Year Ended December 31, 2006

    Management’s
      Discussion and Analysis, page 19

    Liquidity
      and Capital Resources, page 29

            1.

              We
                note that you disclose an adjusted working capital measure as of
                December
                31, 2006 and 2005. As this is a non-GAAP measure, please provide
                the
                disclosures required under Item 10(e)(1)(i)(A), (C) and (D) of Regulation
                S-K, addressing the reasons for the change in the corresponding GAAP-based
                measure disclosed, also setting forth the reasons you believe the
                measure
                is meaningful and explaining how the measure is utilized.

                  curtis, mallet-prevost, colt & mosle
                    llp

                       Mr.
                      Karl Hiller

                       Attorneys
                    and
                    Counselors at Law

                     U.S.
                      Securities and Exchange Commission

                     April
                      25, 2007

                       Page
                      2

    Response:

    The
      Company advises the Staff that in future filings, we will not disclose the
      “adjusted working capital” measure.

    Financial
      Statements

    Note
      1
      - Summary of Significant Accounting Policies, page 45

            2.

              We
                note your subsidiary Nordural ehf derives substantially all of its
                revenues from tolling arrangements. Please clarify in your accounting
                policy disclosure how you account for the tolling contracts. Please
                also
                expand your disclosure sufficiently to explain how the physical conveyance
                of product or rendering of service for each of your revenue generating
                activities corresponds to the timing of recognition established in
                meeting
                the criteria set forth in SAB Topic 13.A.I.

    Response:

    The
      Company advises the Staff that, in future filings, we will expand the disclosure
      of our revenue recognition policies presented under Note 1 (“Summary of
      Significant Accounting Policies”) to our Audited Financial Statements to read as
      follows:

    Revenue
      — The
      Company recognizes revenue from the sale of primary aluminum and from tolling
      fees which the Company earns from smelting alumina supplied by customers.
Revenue
      from the sale of primary aluminum is recognized when title, ownership and risk
      of loss pass to the customer in accordance with contract terms, the price to
      the
      customer is fixed or determinable and collectibility is reasonably assured.
      In
      some instances, we invoice our customers prior to physical shipment of goods.
      In
      such instances, revenue is recognized only when the customer has specifically
      requested such treatment and has made a fixed commitment to purchase the
      product. The goods must be complete, ready for shipment and physically separated
      from other inventory with risk of ownership passing to the customer. We must
      retain no performance obligations and a delivery schedule must be obtained.
      Sales returns and allowances are treated as a reduction of sales and are
      provided for based on historical experience and current estimates.

    The
      Company recognizes revenue from its alumina toll conversion operations when
      the
      toll conversion process is complete in accordance with contract terms (i.e.,
      when the customer’s alumina has been converted to aluminum, cast, palletized and
      weighed for shipment to the customer), the price to the customer is fixed or
      determinable and collectibility is reasonably assured.

            3.

              We
                note your disclosure on page 46, concerning goodwill and intangible
                assets, stating that in April 2005, you capitalized a $7 million
                “post-closing payment” related to the acquisition of Hawesville, which you
                acquired in April 2001. The guidance in SFAS 141, paragraph 40, generally
                limits adjustments to the purchase price for pre-acquisition contingencies
                to the “allocation period,” which usually does not exceed one year from
                the consummation of a business combination, using the definition
                in
                Appendix F. Please tell us why you believe this guidance does not
                apply to
                you, under the circumstances.

                    curtis, mallet-prevost, colt & mosle
                      llp

                         Mr.
                        Karl Hiller

                         Attorneys
                      and
                      Counselors at Law

                       U.S.
                        Securities and Exchange Commission

                       April
                        25, 2007

                         Page
                        3

    Response:

    The
      Company advises the Staff that the $7 million payment was not to settle a
      pre-acquisition contingency as defined in Appendix F of SFAS 141, as the
      contingency did not exist before our acquisition of Hawesville. Rather, the
      post-closing payment was required to be made under the Hawesville acquisition
      agreement if the LME price for primary aluminum exceeded specified levels during
      any of the seven years following closing and is contingent consideration as
      defined by APB 16 paragraph 77 (or SFAS 141 paragraph 25).

    The
      Hawesville acquisition was completed in April 2001 prior to the issuance of
      SFAS 141. We followed the guidance in APB 16 in accounting for the business
      combination. Given the nature of the contingency, the Company applied the
      guidance from APB 16 paragraphs 79 and 80, which state:

    “Contingent
      consideration should usually be recorded when the contingency is resolved and
      consideration is issued or becomes issuable.  In general, the issue of
      additional securities or distribution of other consideration at resolution
      of
      contingencies based on earnings should result in an additional element of cost
      of an acquired company.

    Additional
      consideration may be contingent on maintaining or achieving specified earnings
      levels in future periods.  When the contingency is resolved and additional
      consideration is distributable, the acquiring corporation should record the
      current fair value of the consideration issued or issuable as additional cost
      of
      the acquired company.”

    Accordingly,
      the Company did not record a liability at the time of the acquisition. The
      Company disclosed the possibility of the post-closing payments, and its maximum
      potential, in subsequent filings.

    In
      the
      period April 2004 to March 2005, the LME price for primary aluminum was high
      enough to trigger a payment of $7 million.

    By
      the
      time of the payment, SFAS 141 had replaced APB 16 as the appropriate
      guidance. Because the payment was triggered by high LME prices, which have
      a
      direct relationship to the earnings of Hawesville, the guidance in paragraph
      28
      of SFAS 141 was followed. This paragraph states that for contingencies based
      on
      earnings that:

    “Additional
      consideration may be contingent on maintaining or achieving specified earnings
      levels in future periods.  When the contingency is resolved and additional
      consideration is distributable, the acquiring entity shall record the fair
      value
      of the consideration issued or issuable as an additional cost of the acquired
      entity.”

    Consistent
      with this guidance, the Company increased the cost of the acquired
      asset.

                     curtis, mallet-prevost, colt & mosle
                      llp

                         Mr.
                        Karl Hiller

                         Attorneys
                      and
                      Counselors at Law

                       U.S.
                        Securities and Exchange Commission

                       April
                        25, 2007

                         Page
                        4

    Note
      19 - Condensed Consolidating Financial Information, page 72

            4.

              Please
                advise us as to whether you are able to make the representation and
                disclosures required under Rule 3-10(i)(8) of Regulation S-X, as
                would
                generally be required to qualify for the exception to the general
                rule set
                forth in paragraph (a)(1).

    Response:

    The
      Company advises the Staff that (i) each subsidiary guarantor is 100% owned
      by
      the Company, (ii) all guarantees are full and unconditional, and (iii) all
      guarantees are joint and several. The Company further advises the Staff that
      it
      will include the disclosures required under Rule 3-10(i)(8) of Regulation S-X
      in
      future filings.

    In
      connection with responding to the Staff's comments, the Company acknowledges
      that:

            ·

              the
                Company is responsible for the adequacy and accuracy of the disclosure
                in
                the filing;

            ·

              Staff
                comments or changes to disclosure in response to Staff comments do
                not
                foreclose the Commission from taking any action with respect to the
                filing; and

            ·

              the
                Company may not assert Staff comments as a defense in any proceeding
                initiated by the Commission or any person under the federal securities
                laws of the United States.

    Should
      you have any questions or comments relating to this letter, kindly contact
      the
      undersigned at 212-696-6918.

    Very
      truly yours,

    /s/
      Jeffrey N. Ostrager

    Jeffrey
      N. Ostrager

    cc:
      Nasreen Mohammed

    Michael
      A. Bless, Century Aluminum Company