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SEC Company Response from MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — May 25, 2011

MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: May 25, 2011 · CIK: 0001333274 · Accession: 0000950123-11-053862

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Referenced dates: May 18, 2011, May 25, 2011

Date
May 25, 2011
Author
Richard Short
Form
CORRESP
Company
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)

Letter

SECURITIES AND EXCHANGE COMMISSION Division of Corporation Finance 100 F Street, NE Washington, DC Attention: Susann Reilly

Dear Sirs/Mesdames:

Re: Letter dated May 18, 2011 from the Securities and Exchange Commission (the “Commission”) relating to the Mercer International Inc. (the “Company”) Annual Report on Form 10-K for the fiscal year ended December 31,

In connection with the above-referenced letter and the Company’s responses thereto set forth in a letter dated May 25, 2011 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 comments 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 the federal securities laws of the United States.

Yours truly,

MERCER INTERNATIONAL INC.

By: /s/ Richard Short

Richard Short

Controller

MERCER INTERNATIONAL INC.

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

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CORRESP
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filename1.htm

Correspondence

May 25, 2011

SECURITIES AND EXCHANGE COMMISSION

Division of Corporation Finance

100 F Street, NE

Washington, DC
20549

Attention: Susann Reilly

Dear Sirs/Mesdames:

Re: Letter dated May 18,
2011 from the Securities and Exchange Commission (the “Commission”)
relating to the Mercer International Inc. (the “Company”) Annual
Report on Form 10-K for the fiscal year ended December 31,
2010

In connection with the
above-referenced letter and the Company’s responses thereto set forth in
a letter dated May 25, 2011 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 comments 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 the
federal securities laws of the United States.

Yours truly,

MERCER INTERNATIONAL INC.

By: /s/ Richard
Short

Richard Short

Controller

MERCER INTERNATIONAL INC.

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