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SEC Company Response from Huntsman CORP (HUN) (CIK 0001307954) (HUN) — Feb 8, 2005

Huntsman CORP (HUN) (CIK 0001307954)
Date: Feb. 8, 2005 · CIK: 0001307954 · Accession: 0001047469-05-002748

AI Filing Summary & Sentiment

File numbers found in text: 333-120749

Date
February 8, 2005
Author
HUNTSMAN CORPORATION
Form
CORRESP
Company
Huntsman CORP (HUN) (CIK 0001307954)

Letter

[HUNTSMAN LETTERHEAD]

February 8, 2005

Via EDGAR and facsimile: (202) 942-9531

U.S. Securities and Exchange Commission

Division of Corporation Finance

Judiciary Plaza

450 Fifth Street, N.W.

Washington, D.C. 20549-0510

Attn: Pamela A. Long

Lesli Sheppard

Re: Huntsman Corporation

Registration Statement on Form S-1, File No. 333-120749

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Huntsman Corporation, a Delaware corporation (the "Company"), hereby requests acceleration of the effective time of its Registration Statement on Form S-1, as amended (File No. 333-120749), to February 10, 2005 at 3:30 p.m., Eastern time, or as soon thereafter as practicable.

The Company hereby acknowledges that:

•should the Securities and Exchange Commission (the "Commission") or the staff thereof (the "Staff"), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•the Company may not assert such action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions, please call the undersigned at (801) 584-5830 or Creighton Smith of Vinson & Elkins, L.L.P. at (713) 758-3278.

Very truly yours,
HUNTSMAN CORPORATION

Show Raw Text
CORRESP
1
filename1.htm

[HUNTSMAN LETTERHEAD]

February 8, 2005

Via EDGAR and facsimile: (202) 942-9531

U.S. Securities and Exchange Commission

Division of Corporation Finance

Judiciary Plaza

450 Fifth Street, N.W.

Washington, D.C. 20549-0510

Attn:    Pamela
A. Long

             Lesli Sheppard

Re:       Huntsman
Corporation

             Registration Statement on Form S-1, File No. 333-120749

Ladies
and Gentlemen:

        Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Huntsman Corporation, a Delaware corporation (the "Company"), hereby requests acceleration of the effective
time of its Registration Statement on Form S-1, as amended (File No. 333-120749), to February 10, 2005 at 3:30 p.m., Eastern time, or as soon thereafter as practicable.

        The
Company hereby acknowledges that:

•should
the Securities and Exchange Commission (the "Commission") or the staff thereof (the "Staff"), acting pursuant to delegated authority, declare the filing effective, it
does not foreclose the Commission from taking any action with respect to the filing;

•the
action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

•the
Company may not assert such action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

        If
you have any questions, please call the undersigned at (801) 584-5830 or Creighton Smith of Vinson & Elkins, L.L.P. at (713) 758-3278.

Very truly yours,

HUNTSMAN CORPORATION

By:

/s/  SAMUEL D. SCRUGGS

Name:
Samuel D. Scruggs

Title:
Executive Vice President, General Counsel and Secretary