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CORRESP
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NEWPAGE HOLDING CORPORATION

Courthouse
Plaza, NE

Dayton,
OH 45463

October  31, 2005

VIA EDGAR

  Securities and Exchange
  Commission

  450 Fifth Street, N.W.

  Washington, D.C. 20549

  Re:

  NewPage Holding
  Corporation

Dear Sirs:

NewPage Holding Corporation
(the “Issuer”) is filing today a registration statement on Form S-4 (the “Registration
Statement”).  Terms used herein and not
defined herein shall have the meanings assigned to them in the Registration
Statement.  The Issuer is registering the
offer to exchange its Floating Rate Senior PIK Notes due 2013, Series B (“New
Notes”) for any or all outstanding Floating Rate Senior PIK Notes due 2013,
Series A (“Original Notes”) of the Issuer (the “Exchange Offer”) in
reliance on the position of the Staff (the “Staff”) of the Division of
Corporation Finance of the Securities and Exchange Commission (the “Commission”)
enunciated in Exxon Capital Holdings Corporation (available May 13, 1988) (the “Exxon
Capital Letter”) and other interpretative letters to similar effect.

The Issuer will make each
person participating in the Exchange Offer aware that if such person is a
broker-dealer holding Original Notes acquired for its own account as a result
of market-making activities or other trading activities and receives New Notes
in exchange for such Original Notes pursuant to the Exchange Offer, such
broker-dealer may be a statutory “underwriter” and must acknowledge that it
will deliver a prospectus meeting the requirements of the Securities Act of
1933, as amended (the “Securities Act”), in connection with any resale of such
New Notes.  By reason of such
acknowledgement and prospectus delivery, a broker-dealer will not be deemed to
admit that it is an “underwriter” within the meaning of the Securities
Act.  The Prospectus included in the
Registration Statement, as it may be amended or supplemented from time to time,
may be used by a broker-dealer in connection with resales of New Notes received
for such Original Notes where such Original Notes were acquired in the manner
described above.

The Issuer has not entered
into any arrangement or understanding with any person to distribute the New
Notes to be received in the Exchange Offer and, to the best of the Issuer’s

information
and belief, each person participating in the Exchange Offer is acquiring the
New Notes in its ordinary course of business and has no arrangement or
understanding with any person to participate in the distribution of the New
Notes to be received in the Exchange Offer.
In this regard, the Issuer will make each person participating in the
Exchange Offer aware that if such person is participating in the Exchange Offer
for the purpose of distributing the New Notes to be acquired in the Exchange
Offer, such person (i) could not rely on the Staff position enunciated in the
Exxon Capital Letter or interpretative letters to similar effect and (ii) must
comply with the registration and prospectus delivery requirements of the
Securities Act in connection with a secondary resale transaction.  The Issuer acknowledges that such a secondary
resale transaction by such persons participating in the Exchange Offer for the
purpose of distributing the New Notes should be covered by an effective
registration statement containing the selling securityholder information required
by Item 507 of Regulation S-K.

The Issuer will include in
the Letter of Transmittal to be executed by each person participating in the
Exchange Offer a representation to the effect that, by accepting the Exchange
Offer, such person represents to the Issuer that it is not engaged in, and does
not intend to engage in, a distribution of the New Notes (other than any
broker-dealer, who shall represent that it will comply with the registration
and prospectus delivery requirements of the Securities Act in connection with
any resale of New Notes received in the Exchange Offer).

  NEWPAGE HOLDING
  CORPORATION

  By:

  /s/ Matthew L. Jesch

  Name:

  Matthew L. Jesch

  Title:

  Vice President and Chief
  Financial Officer

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