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GrafTech International Ltd. |
April 16, 2018
VIA EDGAR
Amanda Ravitz
Assistant Director
Office of Electronics and Machinery
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: GrafTech International Ltd.
Registration Statement on Form S-1 (File No. 333-223791)
Dear Ms. Ravitz:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, GrafTech International Ltd. (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form S-1, as amended, be accelerated so that it will be declared effective by 3:00 p.m., Eastern Time, on April 18, 2018 (the “Effective Date”), or as soon as possible thereafter. We ask, however, that the Registration Statement not be declared effective until you speak to our counsel on the Effective Date.
Please contact Sandra L. Flow of Cleary Gottlieb Steen & Hamilton LLP, counsel to the Company, at (212) 225-2494, prior to declaring the Registration Statement effective on the Effective Date, or if you have any other questions or concerns regarding this matter.
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Very truly yours, |
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/s/ Quinn J. Coburn |
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Quinn J. Coburn |
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Vice President, Chief Financial Officer and Treasurer |
cc: Tom Jones
Kristen Lochhead
Brian Cascio
Securities and Exchange Commission
Sandra L. Flow
Adam Fleisher
Alejandro Canelas Fernandez
Cleary Gottlieb Steen & Hamilton LLP