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SEC Company Response from MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Apr 5, 2012

MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: April 5, 2012 · CIK: 0001333274 · Accession: 0001193125-12-152434

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File numbers found in text: 333-179809

Date
April 5, 2012
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 20549

Re: Mercer International Inc. (the “Company”)

Dear Sirs/Mesdames:

Registration Statement on Form S-4

File No.: 333-179809

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 2:00 p.m., New York City time, on April 9, 2012, 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.

Yours truly,

MERCER INTERNATIONAL INC.

/s/ Richard Short

Richard Short

Controller

cc. H. Sangra, Sangra Moller LLP

Andrew Bond, Sangra Moller LLP

MERCER INTERNATIONAL INC.

SUITE 1120, 700 WEST PENDER STREET, VANCOUVER, BC V6C 1G8 T: (604) 684-1099 F: (604) 684-1094

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CORRESP
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Correspondance

 April 5, 2012

 SECURITIES AND EXCHANGE COMMISSION

 Division of Corporation Finance

100 F Street, NE

 Washington, DC 20549

 Dear Sirs/Mesdames:

Re:
Mercer International Inc. (the “Company”)

Registration Statement on Form S-4

File No.: 333-179809

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 2:00 p.m., New York City time, on April 9, 2012, 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.

 Yours truly,

 MERCER INTERNATIONAL INC.

 /s/ Richard Short

Richard Short

 Controller

cc.
    H. Sangra, Sangra Moller LLP

    Andrew Bond, Sangra Moller LLP

 MERCER INTERNATIONAL INC.

 SUITE 1120, 700 WEST PENDER STREET, VANCOUVER, BC V6C
1G8     T: (604) 684-1099    F: (604) 684-1094