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CORRESP
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SHERRITT INTERNATIONAL CORPORATION

Bay Adelaide Centre East Tower

22 Adelaide St. West, Suite 4220

Toronto, ON M5H 4E3

April 10, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, N.E.

Washington, D.C. 20549-3561

    Attention:

    Timothy Levenberg

    Kevin Dougherty

    Daniel Morris

    Re:

    Sherritt International Corporation and the Co-Applicants

    Application for Qualification of Indenture on Form T-3

    File No. 022-29121

Ladies and Gentlemen:

We refer to the Application for Qualification
of Indenture on Form T-3 with respect to the 9.25% Senior Second Lien Secured Notes due 2031, originally filed on March 7, 2025,
and amended on April 2, 2025 and April 9, 2025 (File No. 022-29121) (as amended, the “Form T-3”),
of Sherritt International Corporation (the “Company”) and the other co-applicants identified in the Form T-3 (the
 “Co-Applicants”).

In accordance with Section 307(c) of
the Trust Indenture Act of 1939, as amended, the Company, on behalf of itself and the Co-Applicants, hereby requests acceleration of the
effective date of the above-referenced Form T-3 as of 4:30 p.m. Eastern Time, on Tuesday, April 15, 2025, or as soon
as possible thereafter.

If the Staff of the United States Securities and
Exchange Commission has any questions, please contact Daniel Masliyah of Torys LLP at dmasliyah@torys.com or 1 (212) 880-6032.

  Sincerely,

    SHERRITT INTERNATIONAL CORPORATION

    By:
    /s/ E.A. (Ward) Sellers

    Name: E.A. (Ward) Sellers

    Title: Senior Vice President, General Counsel and Corporate Secretary

    cc:
    Daniel Masliyah, Torys LLP

    Chris Bornhorst, Torys LLP