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Curtis, Mallet-Prevost, Colt & Mosle llp

    Frankfurt

    Milan

    Attorneys and Counsellors at Law

    Houston

    Muscat

    101 Park Avenue

    Istanbul

    Paris

    New York, New York 10178—0061

    Telephone 212-696-6000

    London

    Stamford

    Facsimile 212-697-1559

Mexico City

    Washington, D.C.

    E-Mail info@cm-p.com

    Internet www.cm-p.com

               January 2, 2008

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 comment raised in the letter dated December 18, 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 is the Company’s response to the Staff’s comment. To facilitate your
review, the Staff comment, as set forth in the Comment Letter, is reprinted in italics, and is
followed by the Company’s response.

Performance Shares, page 17

    1.

    We note your response to prior comment 12, and we reissue the comment. Given the reference
to goals and quantifiable targets in your response to prior comments 5 and 12 and in the proxy
statement, it is unclear why you believe that the information is not required. Please explain
in reasonable detail the reasons for believing that the goals and targets are not material to
your compensation determinations. If you believe the disclosure of goals and quantifiable
targets will result in competitive harm, please provide a detailed analysis supporting that
conclusion.

    curtis, mallet-prevost, colt & mosle llp

    Attorneys and Counsellors at Law

    Page 2

    January 2, 2008

Response:

     As disclosed under “Our Compensation Programs — Performance Shares” on pages 17 — 18
of the definitive proxy statement, the Compensation Committee set both (i) strategic and
(ii) operational/financial goals for the 2006-2008 performance program period. As set forth
in the Company’s original response to the Staff’s prior comment 12, the Company believes
that its disclosure regarding these performance goals properly discloses all material
elements within the meaning of Item 402(b)(1) of Regulation S-K. We explain below in
greater detail the reasons for the Company’s determination.

     The proxy statement discloses that the (i) strategic and (ii) operational/financial
goals are each weighted equally, or 50% each. The proxy statement discloses all of the
strategic goals considered by the Committee, with the exception of a single confidential
strategic goal (the “Undisclosed Goal”). The Undisclosed Goal’s weighting in the overall
strategic goals was not material, and the Company disclosed at least seven specific
strategic goals in the proxy statement, some of which actually encompassed multiple goals.
Accordingly, the Undisclosed Goal as a percentage weighting of the strategic goals
represented substantially less than 10% of the overall strategic goals (and, accordingly,
less than 5% of the overall performance goals). In addition, as discussed in more detail
below, the overall determination of performance share awards is subject to the Committee’s
discretion. The Company also wishes to advise the Staff that the proxy statement does not
omit any quantitative disclosure for the strategic goals that are disclosed. As disclosed
in the proxy statement, the strategic goals were predominantly qualitative measures, which
are subject to the Committee’s subjective assessment and evaluation.

     The proxy statement discloses all of the operational/financial goals considered by the
Committee. The Company does not believe that the quantitative targets for these
operational/financial goals are material because (i) the measurement and assessment of the
operational/financial goals is subject to adjustment by the Committee based on price changes
in the LME and Midwest premium prices for aluminum and other conditions affecting
performance, and (ii) the Committee in all cases retains discretion to adjust awards. With
regard to the adjustment of financial goals, the proxy statement on page 18 states the
following: “Because our financial performance is highly dependent on the price of aluminum,
the Committee retains discretion to adjust the operational/financial goals performance
criteria to reflect changes in the London Metals Exchange and the Midwest transactions
prices of aluminum and other conditions affecting performance during a performance program
period, and regularly does so.” With regard to the Committee’s overall retention of
discretion, the Company’s Amended and Restated 1996 Stock Incentive Plan Implementation
Guidelines for Performance Share Awards (As Amended June 8, 2006) specifically provides that
the Committee retains “full and complete discretion to modify any award otherwise payable
[under the performance shares] in light of considerations deemed appropriate by the
Committee. This discretion shall include the right to determine that no award should be
payable.” The Committee exercises this discretion to assure that the level of overall
executive

    curtis, mallet-prevost, colt & mosle llp

    Attorneys and Counsellors at Law

    Page 3

    January 2, 2008

compensation is appropriate. Finally, the Company also wishes to advise the Staff that
the Company’s combined financial goals relating to free cash flow and operating income
(which are subject to adjustment and the Committee’s overall discretion, as explained above)
only account for 30% of the total weighting of performance goals.

     In future filings, where specific quantitative or qualitative performance-related
targets are material, the Company will disclose such targets or otherwise comply with the
requirements of Instruction 4 to Item 402(b) of Regulation S-K.

     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:

    Logan W. Kruger, Century Aluminum Company

Robert R. Nielsen, Century Aluminum Company

William J. Leatherberry, Century Aluminum Company