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SEC Comment Letter for MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Oct 7, 2019

MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: Oct. 7, 2019 · CIK: 0001333274 · Accession: 0000000000-19-014349

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File numbers found in text: 333-234039

Date
October 7, 2019
Author
David M. Gandossi
Form
UPLOAD
Company
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)

Letter

October 7, 2019 David M. Gandossi 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-3 Filed October 1, 2019 File No. 333-234039 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 Sergio Chinos, Staff Attorney, at (202) 551-7844 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Rod Talaifar

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October 7, 2019
David M. Gandossi
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-3
Filed October 1, 2019
File No. 333-234039
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 Sergio Chinos, Staff Attorney, at (202) 551-7844 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Rod Talaifar