Momentive Specialty Chemicals Inc.
180 East Broad Street
Columbus, Ohio 43215
February 11, 2014
VIA EDGAR
John Cash
Accounting Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-3628
Re: | Momentive Specialty Chemicals Inc. |
Form 10-K for the Year Ended December 31, 2012 |
Filed April 1, 2013 |
Form 10-K/A for the Year Ended December 31, 2012 |
Filed November 7, 2013 |
File No. 1-71 |
Dear Mr. Cash:
Momentive Specialty Chemicals Inc. (the “Company”) acknowledges receipt of the comment letter dated February 6, 2014 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) concerning the above-captioned Annual Report onForm 10-K filed April 1, 2013 and the above-captioned Amendment No.1 to the Annual Report on Form 10-K filed November 7, 2013.
In response to the Staff’s comment, the Company hereby acknowledges that:
• | The Company is responsible for the adequacy and accuracy of the disclosure in their filings; |
• | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
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2
We appreciate the Staff’s comments and request the Staff contact the undersigned at (614) 225-2066 or (614) 225-7299 (facsimile) with any questions or comments regarding this letter.
Sincerely, |
/s/ William H. Carter |
William H. Carter |
Executive Vice President and Chief Financial Officer |
cc: | Douglas A. Johns, Esq., Momentive Specialty Chemicals Inc. |
David S. Huntington, Esq., Paul, Weiss, Rifkind, Wharton & Garrison LLP