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SEC Company Response from MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Nov 12, 2009

MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: Nov. 12, 2009 · CIK: 0001333274 · Accession: 0000950123-09-061658

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File numbers found in text: 333-159617

Date
November 12, 2009
Author
David M. Gandossi
Form
CORRESP
Company
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)

Letter

VIA EDGAR UNITED STATES SECURITIES AND EXCHANGE COMMISSION Division of Corporation Finance 100F Street, N.E. Washington, D.C. 20549 Attention: Cathey Baker

Dear Sirs/Mesdames:

Re:

Mercer International Inc.

Registration Statement on Form S-3

File No. 333-159617

Request for Acceleration

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned registrant, Mercer International Inc., a Washington corporation (the “Registrant”), hereby requests that the above-referenced Registration Statement be declared effective at 2 p.m., New York City time, on November 16, 2009, or as soon as practicable thereafter.

The Registrant hereby acknowledges that:

(i)

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(ii)

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii)

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

Very truly yours,
MERCER INTERNATIONAL INC.

Show Raw Text
CORRESP
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filename1.htm

corresp

November 12, 2009

VIA EDGAR

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Division of Corporation Finance

100F Street, N.E.

Washington, D.C. 20549

Attention: Cathey Baker

Dear Sirs/Mesdames:

    Re:

    Mercer International Inc.

Registration Statement on Form S-3

File No. 333-159617

Request for Acceleration

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned
registrant, Mercer International Inc., a Washington corporation (the “Registrant”), hereby requests
that the above-referenced Registration Statement be declared effective at 2 p.m., New York City
time, on November 16, 2009, or as soon as practicable thereafter.

The Registrant hereby acknowledges that:

    (i)

    should the Securities and Exchange Commission (the “Commission”) or the staff,
acting pursuant to delegated authority, declare the Registration Statement effective,
it does not foreclose the Commission from taking any action with respect to the
Registration Statement;

    (ii)

    the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not relieve the
Registrant from its full responsibility for the adequacy and accuracy of the disclosure
in the Registration Statement; and

    (iii)

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

Very truly yours,

    MERCER INTERNATIONAL INC.

    By:
    /s/ David M. Gandossi

    Name:
    David M. Gandossi

    Title:
    Secretary and Chief Financial Officer

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