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CORRESP

Curtis, Mallet-Prevost, Colt & Mosle llp

    Attorneys and Counsellors at Law

    Frankfurt

    Milan

    101 Park Avenue

    Houston

    Muscat

    New York, New York 10178-0061

    Telephone 212-696-6000

    Istanbul

    Paris

    Facsimile 212-697-1559

    London

    Stamford

    E-Mail info@cm-p.com

    Mexico City

    Washington, D.C.

    Internet www.cm-p.com

    November 1, 2007

VIA EDGAR AND FACSIMILE

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC  20549

Attention:  Carmen Moncada-Terry, Attorney Advisor

    Re:

    Century Aluminum Company

    Definitive Proxy Statement on Schedule 14A

    Filed April 23, 2007

    File No. 000-27918

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 September 26, 2007
(the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”)to Mr. Logan W. Kruger, President and Chief Executive 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.

Certain Relationships and Related Transactions, page 11

Approval of Transactions in 2006, page 11

    1.

    We refer you to Item 404(a) of Regulation S-K. Elaborate on the market prices of alumina
and/or its by-products purchased and sold to Glencore during 2006. Specifically, please
clarify why you reference the “approximate market” prices of the transactions. Identify the
percentage of transactions at market price. Where there were divergences, explain the process
of approval of such transactions and the dollar amount of the divergence if required by Item
404(a) of Regulation S-K.

    Curtis, Mallet-Prevost, Colt & Mosle LLP

    Attorneys and Counsellors at Law

    Page 2

    November 1, 2007

     Response:

     Primary aluminum is an internationally traded commodity and its price is effectively
determined based on the price for primary aluminum on the London Metal Exchange
(“LME”). Because of market supply imbalances within the United States, products
delivered to U.S. customers are sold at a premium to the LME price (the “Midwest
Premium”). This premium generally relates to (1) the additional transportation cost
foreign suppliers have to incur to deliver aluminum to the U.S. market and (2) the relative
demand existing in the other two short supply markets, being Europe and Japan.
Additionally, premiums are charged for adding certain alloys to aluminum for use in specific
applications and for casting aluminum into specific shapes, such as extrusion billet or
rolling slab. The market price for alumina, which is the primary raw material used in the
production of primary aluminum, is also based on the LME price for primary aluminum.

     In 2006, the Company purchased $181.1 million of alumina from Glencore under long-term
alumina supply contracts at prices that were based on the LME price for primary aluminum.
The Company believes that 100% of the alumina purchased under these contracts was purchased
at market prices. The Company also purchased $4.5 million of alumina from Glencore in May
2006 on a “spot” basis. The Company determined the market price for the spot alumina it
purchased based on a survey of suppliers at the time that had the ability to deliver spot
alumina on the specified terms. Based on this survey, the Company believes that 100% of the
spot alumina purchased from Glencore in 2006 was purchased at market prices.

     In 2006, the Company sold $180.5 million in primary aluminum under the Company’s
long-term sales contracts with Glencore at prices based on the LME price for primary
aluminum, as adjusted to reflect the Midwest Premium. Additionally, the Company received
$79.0 million in tolling fees from Glencore in 2006 under a tolling contract that provides
for delivery of primary aluminum produced at the Company’s Nordural facility. The fee paid
by Glencore under this tolling contract is based on the LME price for primary aluminum, as
adjusted to reflect the reduced European Union import duty paid on Icelandic primary
aluminum. The Company believes that 100% of the transactions with Glencore under these
contracts were at market prices.

     In 2006, the Company also sold $3.9 million in primary aluminum to Glencore on a “spot”
basis. The Company determined the market price for the spot aluminum it sold based on a
survey of potential buyers that were able to purchase the aluminum where and when available
and that met the credit requirements of the Company. Based on this survey, the Company
believes that all spot sales of primary aluminum to Glencore in 2006 were made at market
prices.

     The Company refers to the “approximate market” prices of transactions with Glencore
based upon the method used for determining the market price of purchases and sales on a
“spot” basis, as described above. The Company believed it was appropriate to

    Curtis, Mallet-Prevost, Colt & Mosle LLP

    Attorneys and Counsellors at Law

    Page 3

    November 1, 2007

qualify its reference to market prices because the price surveys it conducted in
connection with spot purchases and sales were limited in scope. In future filings, the
Company will expand its disclosure to include the basis for any determination that spot
purchases and sales are made at market prices whenever such determination is made based on
similar surveys. In future filings, the Company will also specify the percentage of
transactions with Glencore that were not made at market prices, if any, and where there were
divergences, will explain the process of approval of such transactions and the dollar amount
of the divergences.

    2.

    Please clarify whether any of the purchases and sales referenced in 2006 would fall under the
category of transactions that are deemed to be within the ordinary course of transactions
with Glencore in accordance with the new written related party transaction policy enacted in
March 2007.

    Response:

     Other than transactions pursuant to long-term contracts that were previously approved
by the Company’s Audit Committee, all transactions with Glencore in 2006 fell within the
category of transactions with Glencore that are deemed to be in the ordinary course under
the Company’s new written related party transaction policy adopted in March 2007.

     Although not required to do so under the related party transaction policy adopted in
March, 2007, the Company’s Audit Committee or a special committee of independent directors,
reviews and approves all transactions with Glencore, including those that are
ordinary-course transactions under the policy. Accordingly, in 2006 the Audit Committee or
a special committee of independent directors reviewed and approved all ordinary course
transactions with Glencore that were not otherwise subject to review, approval or
ratification under the Company’s related party transaction policy. The Company discloses on
page 11 of the definitive proxy statement, and will disclose in future filings, whether all
transactions with Glencore are approved by the Audit Committee or a special committee of
independent directors.

2006 Director Compensation, page 7

    3.

    You refer to changes made to director compensation in August 2006. Concisely describe the
changes made and address the rationale in instituting them.

    Response:

    In August 2006, the Company’s Compensation Committee approved the following changes to
non-employee director compensation:

    –

    the annual retainer for non-employee directors was increased from
$25,000 to $35,000;

    Curtis, Mallet-Prevost, Colt & Mosle LLP

    Attorneys and Counsellors at Law

    Page 4

    November 1, 2007

    –

    the annual retainer for the Chairman of the Audit Committee was
increased from $5,000 to $10,000;

    –

    the Lead Director of the Board receives an additional annual retainer
of $25,000; and

    –

    the Chairman of each of the Compensation and the Governance and
Nominating Committees receives an additional annual retainer of $5,000.

     Prior to August 2006, the annual retainer paid to non-employee directors had not
changed since December 1999. During the time period from 1999 to 2006 the growing size and
scope of the Company’s operations significantly increased the demands on the Company’s
directors. To compensate the non-employee directors for the increase in their
responsibilities and to further the Company’s desire to continue to attract and retain
qualified individuals to serve as directors, the Compensation Committee approved these
changes to the compensation paid to non-employee directors. The Committee did so in part in
reliance on a survey report by Integis, Inc. of comparable companies’ director-compensation
practices.

     In future filings, where there have been changes in non-employee director compensation,
the Company will describe the changes made and address the rationale in instituting them,
doing so where such disclosure is required or appropriate under the Commission’s rule and
regulations.

Stock Options, page 8

    4.

    Please clarify whether the annual grant of stock options is subject to change from year to
year. If yes, discuss the factors the compensation committee considers in determining the
appropriate level of options granted to directors in a given year.

    Response:

     Under the Company’s Amended and Restated 1996 Stock Incentive Plan, the Company’s
Compensation Committee or the Board is authorized to grant options to the Company’s
non-employee directors.

     The annual grant of 3,000 options is subject to change, but has not changed since
January 2003, at which time the grant was increased from 2,000 to 3,000 options as a means
to increase directors’ equity positions in the Company. The Company’s Compensation
Committee determines the amount of the annual grant as part of the overall compensation of
the non-employee directors.

     In future filings, the Company will clarify that the annual grant is subject to change
from year to year. In addition, as we advised in our response to Comment No. 3 above, for
any year where there has been a change in the annual grants of options to non-

    Curtis, Mallet-Prevost, Colt & Mosle LLP

    Attorneys and Counsellors at Law

    Page 5

    November 1, 2007

employee directors, the Company will describe the changes made and the rationale
therefor, doing so where such disclosure is required or appropriate under the Commission’s
rule and regulations.

Executive Compensation, page 13

Compensation Discussion and Analysis, page 13

Our Process for Executive Compensation, page 14

    5.

    Please provide an enhanced discussion of the information required by Item 402(b)(1) of
Regulation S-K. For example, while you indicate that the objectives of your compensation
program are focused on retention and attraction of executives, your disclosure in the
paragraphs that follow suggests the committee also structures the program to focus on
“pay-for-performance,” particularly with respect to performance that promotes the business
objectives of the company. Please clarify these concepts and how you apply them in practice.
Similarly, with respect to Items 402(b)(1)(v)-(vi) of Regulation S-K, please clarify how you
determine amounts earned pursuant to a minimum first year bonus and how these minimum bonuses
fit into the objectives and philosophy of the compensation program. Please revise your
disclosure accordingly.

    Response:

     As the Company discloses in the third paragraph on page 14 of the definitive proxy
statement, the Company’s overall compensation program is designed to provide executives in
an average year with total compensation at or around the mid-range of the total compensation
paid for comparable positions within the surveyed companies. The Company believes that
providing competitive compensation and rewarding its executives for performance is necessary
to attract and retain talented executives and managers. The approach taken by the
Compensation Committee is to use data from the surveyed companies to establish a baseline of
compensation at or around the mid-range, and then to assess company and individual
performance to determine the degree to which an executive’s compensation should be increased
or decreased around that baseline. The Company is thus “paying for performance,” doing so
by way of the Compensation Committee assessing and deciding the degree to which an executive
should be rewarded for his or her performance.

     As further disclosed under “Our Compensation Programs — Short-Term Annual Cash
Incentive Awards,” “— Long-Term Incentive Compensation” and “— Performance Shares” on
pages 16 — 18 of the definitive proxy statement the Compensation Committee awards
discretionary annual bonuses and special bonuses, and retains discretion to determine the
achievement of performance targets for three-year performance share awards in order to
reward short-term and long-term performance.

    Curtis, Mallet-Prevost, Colt & Mosle LLP

    Attorneys and Counsellors at Law

    Page 6

    November 1, 2007

     The Compensation Committee has determined that, based on the Company’s business (i.e.,
a cyclical commodity business) and the Company’s position in its industry, executive
performance is best measured through a combination of (1) strategic goals, and (2)
operational and financial goals. The nature of the strategic goals (which are set in terms
of specific targets with regard to acquisitions, expansions, and securing long-term
contracts for power, labor and alumina) is such that measurement and assessment of
performance against those goals is subject to the Committee’s subjective evaluation. The
measurement and assessment of performance under the operational and financial goals is
subject to adjustment by the Committee based on market forces, such as price changes in the
LME and Midwest premium prices for aluminum (such adjustment being contemplated and allowed
under the Implementation Guidelines and the company’s Amended and Restated 1996 Stock
Incentive Plan). In addition, the Committee retains discretion to determine that no award
shall be payable.

     The Committee has determined that retaining discretion and using such discretion as set
forth above, is necessary to assure that management is appropriately rewarded for
performance.

     In future filings, the Company’s enhanced disclosure of the purposes and application of
the different elements of compensation will discuss the relationship between the stated
objective of attracting and retaining talented executives and managers and the “pay for
performance” elements. In future filings, the Company also will provide enhanced disclosure
regarding the Committee’s evaluation of the achievement of performance goals, the bases upon
which the Committee determined actual awards under the annual bonus and performance share
award programs, and the degree to which the Committee will continue to exercise its
discretion in setting such awards.

     With respect to minimum first year bonuses, the Company discloses under “Short-Term
Annual Cash Incentive Awards” on page 16 of the definitive proxy statement that providing
minimum first year bonuses allows newly hired executive officers to have some certainty as
to their minimum total compensation, which assists the Company in attracting the executives.
Where applicable in future filings, the Company will add disclosure that any minimum first
year bonus is based on negotiations of the employment agreement for a