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SEC Comment Letter for MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Aug 7, 2018

MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: Aug. 7, 2018 · CIK: 0001333274 · Accession: 0000000000-18-024426

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-226443

Date
July 30, 2018
Author
/s/ Kevin M. Dougherty for
Form
UPLOAD
Company
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)

Letter

Mail Stop 4628 August 7 , 2018 David M. Gandossi President and Chief Executive Officer Mercer International Inc. Suite 1120, 700 West Pender Street Vancouver, British Columbia, Canada, V6C 1G8

Re: Mercer International Inc. Registration Statement on Form S-4 Filed July 30, 2018 File No. 333-226443

Dear Mr. Gandossi :

This is to advise you that we have not reviewed and will not review your registration statement .

Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Anuja A. Majmudar, Attorney -Advisor, at 202 -551-3844 with any questions.

Sincerely,
/s/ Kevin M. Dougherty for

Show Raw Text
Mail Stop 4628
August 7 , 2018

David M. Gandossi
President and Chief Executive Officer
Mercer International  Inc.
Suite 1120, 700 West Pender Street
Vancouver, British Columbia, Canada,  V6C 1G8

Re: Mercer International  Inc.
  Registration Statement on Form S-4
Filed  July 30,  2018
  File No.  333-226443

Dear Mr. Gandossi :

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please  contact Anuja A. Majmudar, Attorney -Advisor,  at 202 -551-3844  with any
questions.

Sincerely,

 /s/ Kevin M. Dougherty for

 John Reynolds
Assistant Director
Office of Natural Resources

cc: H.S. Sangra, Esq.
 Sangra Moller LLP