SEC Company Response from MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Sep 22, 2016
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: Sept. 22, 2016 · CIK: 0001333274 · Accession: 0001193125-16-716808
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File numbers found in text: 333-213644
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CORRESP 1 filename1.htm CORRESP September 22, 2016 VIA EDGAR AND FACSIMILE UNITED STATES SECURITIES AND EXCHANGE COMMISSION Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: H. Roger Schwall Dear Sirs/Mesdames: Re: Mercer International Inc. Registration Statement on Form S-3 File No.: 333-213644 Request for Acceleration In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned registrant, Mercer International Inc., a Washington Corporation (the “Registrant”), respectfully requests that the effective date for the above-referenced Registration Statement be accelerated so that it will be declared effective at 2:00 p.m., New York City time, on September 26, 2016, 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 MERCER INTERNATIONAL INC. SUITE 1120, 700 WEST PENDER STREET, VANCOUVER, BC V6C 1G8 T: (604) 684-1099 F: (604) 684-1094 (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. By: /s/ David K. Ure Name: David K. Ure Title: Chief Financial Officer, Senior Vice-President, Finance, and Secretary MERCER INTERNATIONAL INC. SUITE 1120, 700 WEST PENDER STREET, VANCOUVER, BC V6C 1G8 T: (604) 684-1099 F: (604) 684-1094