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Correspondence

Lucite
International UK Limited

Queens Gate

15-17 Queens Terrace

Southampton SO14 3BP

United Kingdom

Tel: +44 (0)2380 248150

Fax: +44 (0)2380 248160

www.luciteinternational.com

October 3, 2005

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington D.C. 20549

    Attention:

    Mr. John Cash

    Ms. Mindy Hooker

    Re:

    Lucite International Group Holdings Ltd.

    Annual Report on Form 20-F filed April 6, 2005

    Current Report on Form 6-K filed August 24, 2005

    File Number 333-12714

Dear Mr. Cash and Ms. Hooker:

     I am responding to the comments set forth in the comment letter from the Commission’s staff
dated September 15, 2005 relating to our Annual Report on Form 20-F for the fiscal year ended
December 31, 2004 and our Current Report on Form 6-K for August 24, 2005.

     Please note that we will separately respond to comments 2 and 3 of your comment
letter by October 31, 2005.

     For your convenience, the numbered paragraph below corresponds to the numbered
paragraph in your comment letter, a copy of which is attached. The page reference below is to our
2004 20-F.

    1.

    2004 20-F: Selected Financial Data — Exchange Rate Information, page 8

     We will expand our disclosure of exchange rates to conform to the staff’s comment in future
filings.

* * * * *

     The undersigned, on behalf of the company, hereby acknowledges that (i) the company is
responsible for the adequacy and accuracy of the disclosure in its filings; (ii) 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 (iii) 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 about the responses in this letter, please feel free to contact
me at +44 (0)238-024-8161.

    Sincerely,

Annie S. Veerman

Chief Financial Officer

Enclosure

Received by Fax: 09/19/2005 10:11

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549-7010

[SEC Division of Corporate Finance Logo]

September 15, 2005

Ms. Annie S. Veerman

Chief Financial Officer, Lucite International Group Holdings Ltd

Queens Gate

15-17 Queens Terrace

Southampton SO14 3BP

United Kingdom

    Re:

    Lucite International Group Holdings Ltd.

    Form 20-F for the fiscal year ended December 31, 2004

    Form 6-K for the period ended June 30, 2005

    File Number 333-12714

Dear Ms. Veerman:

     We have reviewed your filing and have the following comments. Where
indicated, we think you should revise your document in response to these
comments. If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary. Please be as detailed as
necessary in your explanation. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure. After
reviewing this information, we may or may not raise additional comments.

Please understand that the purpose of our review process is to assist you in
your compliance with the applicable disclosure requirements and to enhance the
overall disclosure in your filing. We look forward to working with you in these
respects. We welcome any questions you may have about our comments or on any
other aspect of our review. Feel free to call us at the telephone numbers listed
at the end of this letter.

Form 20-F for the fiscal year ended December 31, 2004

Selected Financial Data — Exchange Rate Information. page 8

    1.

    In future filings please disclose all exchange rates as required
by paragraph 5B of Item 301 of Regulation S-K including a history of
exchange rates for the five most recent years setting forth the rates for
period end, the average rates, and the range of high and low rates for
each year.

Annie Veerman

Lucite International Group Holdings Ltd

September 15, 2005

Page 2

Note 3 — Segmental Reporting, page F-12

    2.

    Based on the description of your business beginning on page 14, it
appears that you may have multiple operating segments as defined by
paragraph 10 of SFAS 131 that you have aggregated into one reportable
segment. Please tell us how you determined that you have two reportable
segments. If you have aggregated operating segments, tell us how you
determined the aggregation to be appropriate based on the guidance
provided in paragraph 17 of SFAS 131. In addition, revise future filings
to provide product-line disclosures as required by paragraph 37 of SFAS
131 or tell us why they are not required.

Form 6-K for the period ended June 30, 2005

Note 6 — EBITDA, page 8

    3.

    We note that you are presenting EBITDA as an operating performance
measure. It also appears that you are presenting EBITDA as a liquidity
measure from your statement that it is accepted as a financial indicator
of the ability to incur and service debt. As such, please revise your
disclosure to provide the following information, as required by Item 10(e)
of Regulation S-K and questions 8 and 12 of the SEC “Frequently Asked
Questions Regarding the Use of Non-GAAP Financial Measures:”

    •

    Performance measure: Expand your discussion of the limitations of
EBITDA to address how the exclusion of each item materially limits
the usefulness of EBITDA. For instance you might expand your disclosures,
in part, to address the limitations of EBITDA as a performance measure by
providing the following information:

    °

    It does not include interest expense. Because we have
borrowed money in order to finance our operations, interest expense is
a necessary element of our costs and ability to generate revenue.
Therefore, any measure that excludes interest expense has material
limitations;

    °

    It does not include depreciation and amortization expense.
Because we use capital assets, depreciation and amortization expense
is a necessary element of our costs and ability to general revenue.
Therefore, any measure that excludes depreciation and amortization
expense has material limitations;

    °

    It does not include taxes. Because the payment of taxes is
a necessary element of our operations, any measure that excludes tax
expense has material limitations.

    •

    Performance measure: State how you compensate for the material
limitations of using EBITDA.

    •

    Performance measure: State the economic substance behind your decision
to use such a measure.

    •

    Performance measure: Please provide substantive reasons why management
believes EBITDA provides useful information to investors.

    •

    Liquidity measure: Reconcile EBITDA to cash flows from operating
activities, as the most comparable liquidity GAAP financial measure, in
addition to reconciling to net income.

    •

    Liquidity measure: Present the three major categories of the statement
of cash flows with equal or greater prominence.

Annie Veerman

Lucite International Group Holdings Ltd

September 15, 2005

Page 3

     As appropriate, please amend your filing and respond to these comments
within 10 business days or tell us when you will provide us with a response.
Please provide us with a supplemental response letter that keys your responses
to our comments and provides any requested supplemental information. Detailed
letters greatly facilitate our review. Please file your supplemental response on
EDGAR as a correspondence file. Please understand that we may have additional
comments after reviewing your responses to our comments.

     We urge all persons who are responsible for the accuracy and adequacy of
the disclosure in the filing to be certain that the filing includes all
information required under the Securities and Exchange Act of 1934 and that they
have provided all information investors require for an informed investment
decision. Since the company and its management are in possession of all facts
relating to a company’s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

     In connection with responding to our comments, please provide, in writing,
a statement from the company acknowledging that:

    •

    the company is responsible for the adequacy and accuracy of the
disclosure in their filings;

    •

    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.

     In addition, please be advised that the Division of Enforcement has access
to all information you provide to the staff of the Division of Corporation
Finance in our review of your filing or in response to our comments on your
filing.

If you have any questions regarding these comments, please direct them to Mindy
Hooker, Staff Accountant, at (202) 551-3732 or to the undersigned at (202)
551-3768.

    Sincerely,

    /s/ John Cash

    John Cash

Branch Chief