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SEC Comment Letter for MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Oct 30, 2019

MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: Oct. 30, 2019 · CIK: 0001333274 · Accession: 0000000000-19-015007

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File numbers found in text: 333-234294

Date
October 30, 2019
Author
David K. Ure
Form
UPLOAD
Company
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)

Letter

October 30, 2019 David K. Ure Chief Financial 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 October 22, 2019 File No. 333-234294 Dear Mr. Ure: 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 Sherry Haywood at (202) 551-3345 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing

Show Raw Text
October 30, 2019
David K. Ure
Chief Financial 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 October 22, 2019
File No. 333-234294
Dear Mr. Ure:
            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 Sherry Haywood at (202) 551-3345 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing