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SEC Company Response from MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Jul 10, 2008

MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: July 10, 2008 · CIK: 0001333274 · Accession: 0000945234-08-000308

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: June 17, 2008, June 27, 2008

Date
June 27, 2008
Author
David Ure
Form
CORRESP
Company
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)

Letter

SECURITIES AND EXCHANGE COMMISSION Division of Corporation Finance Washington, D.C. 20549 Attention: Susann Reilly, Attorney Mail Stop

Dear Sirs/Mesdames:

Re:

Letter dated June 17, 2008 from the Securities and Exchange Commission relating to Mercer International Inc. (the “Company”) Annual Report on Form 10-K for the fiscal year ended December 31, 2007

In connection with the above-referenced letter and the Company’s responses thereto set forth in a letter dated June 27, 2008 from the Company’s counsel, Sangra Moller LLP, enclosed herewith, the Company acknowledges that:

•

The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

Staff comments or changes to disclosure in response to staff comment do not foreclose the Commission from taking any action with respect to the filing; and

•

The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under federal securities laws of the United States.

Very truly yours,
MERCER INTERNATIONAL INC.

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CORRESP
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SEC Acknowledgement Letter

June 27, 2008

VIA FACSIMILE AND COURIER

SECURITIES AND EXCHANGE COMMISSION

Division of Corporation Finance

100F Street, N.E., Mail Stop 3561

Washington, D.C. 20549

    Attention:

    Susann Reilly, Attorney

Mail Stop
3561

Dear Sirs/Mesdames:

    Re:

    Letter dated June 17, 2008 from the Securities and
Exchange Commission relating to Mercer International
Inc. (the “Company”) Annual Report on Form 10-K for the
fiscal year ended December 31, 2007

In connection with the above-referenced letter and the Company’s responses thereto set forth in a
letter dated June 27, 2008 from the Company’s counsel, Sangra Moller LLP, enclosed herewith, the
Company acknowledges that:

    •

    The Company is responsible for the adequacy and accuracy of the disclosure in the
filing;

    •

    Staff comments or changes to disclosure in response to staff comment do not foreclose
the Commission from taking any action with respect to the filing; and

    •

    The Company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under federal securities laws of the United States.

Very truly yours,

MERCER INTERNATIONAL INC.

    By:

/s/  David
Ure

    Authorized Signatory

MERCER INTERNATIONAL INC

SUITE 2840, PO Box 11576 – 650 WEST GEORGIA STREET, VANCOUVER,
BC V6B 4N8    T: (604) 684-1099    F: (604) 684-1094

14009 INTERURBAN AVENUE SOUTH,    SUITE 282    SEATTLE,
WASHINGTON    98168    T: (206) 674
4639    F: (206) 674 4629