[Cellu Tissue Holdings, Inc. Letterhead]
January 19, 2010
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
100 F Street, NE
Washington, DC 20549-3561
Attention: Damon Colbert
Re: | Cellu Tissue Holdings, Inc. |
Registration Statement on Form S-1 |
File No. 333-162543 |
Dear Mr. Colbert:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Cellu Tissue Holdings, Inc. (the “Company”), hereby requests acceleration of the effective date of the Registration Statement on Form S-1 (No. 333-162543) to 1:00 p.m., Washington, D.C. time, on Thursday, January 21, 2010, or as soon thereafter as practicable.
In addition, the Company acknowledges that:
• | should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
• | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
• | the Company 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. |
Securities and Exchange Commission
January 19, 2010
Page 2
Please call the undersigned at (770) 407-2169 or Tracy Kimmel of King & Spalding LLP at (212) 556-2294 if you have any questions.
Sincerely, | ||
Cellu Tissue Holdings, Inc. | ||
By: | /s/ W. Edwin Litton | |
W. Edwin Litton | ||
General Counsel, Senior Vice | ||
President, Human Resources and | ||
Secretary |
cc: | Tracy Kimmel |
King & Spalding LLP |