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    Lucite International Group Holdings 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 28, 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. The company responded to
comment 1 of the comment letter on October 3, 2005.

     The company has also revised the August 6-K in response to the staff’s comments and is filing
concurrently with this letter an amended Current Report on Form 6-K/A, which reflects these
revisions.

     For your convenience, the numbered paragraphs of this letter correspond to the numbered
paragraphs of the comment letter, a copy of which is attached. Page references in this letter are
to pages in the 2004 20-F and August 6-K as indicated.

2. 2004 20-F: Note 3 — Segmental Reporting, page F-12

     We have noted the staff’s comment and have considered the criteria of paragraph 10 of SFAS 131
in our order to provide the staff with information with respect to how we have determined our
operating and reportable segments in accordance with US GAAP.

     The “upstream” and “downstream” components of our business are business activities which earn
revenues and incur expenses and for which discrete financial information is available. The Board
of Directors (the “Board”) for the Lucite International Group makes all decisions relating to the
allocation of resources and assessment of business performance based on the upstream and downstream
components.

     The management reports received by the Board on a monthly basis are prepared based on the
upstream and downstream discrete financial information. No individual product line information is
provided to the Board on an ongoing basis for decision-making purposes or the allocation of
resources.

     Based on the above, we have concluded that our operating segments are the upstream and
downstream components of our business.

     Further, we have considered the aggregation criteria of paragraph 17 of SFAS 131 and believe
that, due to the differences in the nature of the products in our upstream compared to downstream
segments, as well as differences in the nature of the production processes, differences in the end
consumers and differences in the methods used to distribute the upstream compared to downstream
products, the upstream and downstream operating segments do not meet the stated aggregation
criteria.

     As such, we have concluded that our reportable segments under SFAS 131 are the same as our
operating segments.

     Finally, in response to the staff’s comment, we will provide product line disclosures as
required by paragraph 37 of SFAS 131 in future filings. We anticipate categorizing our product
line disclosures as follows: upstream products, polymers and resins, and sheet products.

3. August 6-K: Note 6 — EBITDA, page 8

     In response to the staff’s comment, we have deleted Note 6 of the August 6-K and have
eliminated all references to EBITDA in the amended 6-K. We further confirm that we will not
include references to EBITDA 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