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: 0000950123-11-053868
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 18, 2011
Letter
VIA EDGAR AND COURIER SECURITIES AND EXCHANGE COMMISSION Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Susann Reilly
Dear Sirs/Mesdames:
Re:
Mercer International Inc. (the “Company”)
Form 10-K for the year ended December 31, 2010
Filed February 17, 2011
File No.: 0-51826
We act as counsel for the Company and write in connection with the letter dated May 18, 2011 (the “Comment Letter”) from the Securities and Exchange Commission (the “Commission”) commenting on the Company’s Form 10-K for the year ended December 31, 2010 filed with the Commission on February 17, 2011 (File No.:0-51826). On behalf of the Company, we provide the following response to your comment. For your ease of reference, we have reproduced the numbering in the Comment Letter and have set out below, in italics, the text of your question followed by the Company’s response thereto.
Form 10-K
1)
We note that exhibit 10.16 is missing exhibits, schedules and/or attachments. Please confirm that you will file this exhibit in its entirety with your next periodic report.
The Company acknowledges your comment and advises that it agrees to file exhibit 10.16 in its entirety, including all exhibits, schedules and attachments with its next periodic report on Form 10-Q.
May 25, 2011
Page 2
We trust the foregoing to be in order, but should you have any questions or concerns, please do not hesitate to contact the undersigned at (604) 692-3022 or Andrew Bond of our office at (604) 692-3059.
Yours truly,
SANGRA MOLLER LLP
Per: /s/ H.S. Sangra
H.S. Sangra
Per: /s/ Andrew Bond
Andrew Bond
Washington State Bar No. 39502
California State Bar No. 257763
District of Columbia Bar No. 994014
HSS/AJB/cl
cc.
Mercer International Inc.
Attention: Jimmy S.H. Lee / David M. Gandossi
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CORRESP 1 filename1.htm Correspondence H.S. Sangra 5000160 (604) 692-3022 hsangra@sangramoller.com May 25, 2011 VIA EDGAR AND COURIER SECURITIES AND EXCHANGE COMMISSION Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Susann Reilly Dear Sirs/Mesdames: Re: Mercer International Inc. (the “Company”) Form 10-K for the year ended December 31, 2010 Filed February 17, 2011 File No.: 0-51826 We act as counsel for the Company and write in connection with the letter dated May 18, 2011 (the “Comment Letter”) from the Securities and Exchange Commission (the “Commission”) commenting on the Company’s Form 10-K for the year ended December 31, 2010 filed with the Commission on February 17, 2011 (File No.:0-51826). On behalf of the Company, we provide the following response to your comment. For your ease of reference, we have reproduced the numbering in the Comment Letter and have set out below, in italics, the text of your question followed by the Company’s response thereto. Form 10-K 1) We note that exhibit 10.16 is missing exhibits, schedules and/or attachments. Please confirm that you will file this exhibit in its entirety with your next periodic report. The Company acknowledges your comment and advises that it agrees to file exhibit 10.16 in its entirety, including all exhibits, schedules and attachments with its next periodic report on Form 10-Q. 1 May 25, 2011 Page 2 We trust the foregoing to be in order, but should you have any questions or concerns, please do not hesitate to contact the undersigned at (604) 692-3022 or Andrew Bond of our office at (604) 692-3059. Yours truly, SANGRA MOLLER LLP Per: /s/ H.S. Sangra H.S. Sangra Per: /s/ Andrew Bond Andrew Bond Washington State Bar No. 39502 California State Bar No. 257763 District of Columbia Bar No. 994014 HSS/AJB/cl cc. Mercer International Inc. Attention: Jimmy S.H. Lee / David M. Gandossi 2