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SEC Company Response from TRONOX INC (CIK 0001328910) — Nov 17, 2005

TRONOX INC (CIK 0001328910)
Date: Nov. 17, 2005 · CIK: 0001328910 · Accession: 0001047469-05-027160

AI Filing Summary & Sentiment

File numbers found in text: 333-125574

Date
November 21, 2005
Author
TRONOX INCORPORATED
Form
CORRESP
Company
TRONOX INC (CIK 0001328910)

Letter

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Tronox Incorporated 123 Robert S. Kerr Avenue Oklahoma City, Oklahoma 73102

November 17,

Via EDGAR and Facsimile Number (202) 772-9368

Ms. Pamela A. Long, Assistant Director

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-7010

Mail Stop 7010

Re:Tronox Incorporated

Registration Statement on Form S-1

File No. 333-125574

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, Tronox Incorporated hereby requests that the Securities and Exchange Commission accelerate the effective date of the Registration Statement referred to above so that the Registration Statement will become effective at 4:00 p.m., New York time, on Monday, November 21, 2005, or as soon thereafter as practicable. Tronox Incorporated acknowledges that:

•should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement 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 Tronox Incorporated from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

•Tronox Incorporated may not assert staff comments and the declaration of effectiveness 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 with respect to the foregoing, please contact David B.H. Martin at Covington & Burling at (202) 662-5128.

Very truly yours,
TRONOX INCORPORATED

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CORRESP
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 -- Click here to rapidly navigate through this document

Tronox Incorporated
  123 Robert S. Kerr Avenue
  Oklahoma City, Oklahoma 73102

November 17,
2005

Via EDGAR and Facsimile Number (202) 772-9368

Ms. Pamela A. Long, Assistant Director

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-7010

Mail Stop 7010

Re:Tronox
Incorporated

Registration Statement on Form S-1

File No. 333-125574

Ladies
and Gentlemen:

        Pursuant
to Rule 461 promulgated under the Securities Act of 1933, Tronox Incorporated hereby requests that the Securities and Exchange Commission accelerate the effective date of
the Registration Statement referred to above so that the Registration Statement will become effective at 4:00 p.m., New York time, on Monday, November 21, 2005, or as soon thereafter as
practicable. Tronox Incorporated acknowledges that:

•should
the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement 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 Tronox Incorporated from its full
responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

•Tronox
Incorporated may not assert staff comments and the declaration of effectiveness 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 with respect to the foregoing, please contact David B.H. Martin at Covington & Burling at (202) 662-5128.

Very truly yours,

TRONOX INCORPORATED

By:

/s/   ROGER G. ADDISON       Name: Roger G. Addison

Title: Vice President and General Counsel

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Tronox Incorporated 123 Robert S. Kerr Avenue Oklahoma City, Oklahoma 73102