GrafTech International Ltd. | |
982 Keynote Circle | |
Brooklyn Heights, Ohio USA 44131 | |
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March 23, 2018
BY 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.
Amendment No. 1 to Registration Statement on Form S-1
Filed on March 23, 2018
File No. 333-223791
Dear Ms. Ravitz:
GrafTech International Ltd. (the “Company”) has filed today amendment no. 1 (“Amendment No. 1”) to the registration statement on Form S-1 (File No. 333-223791) filed with the Securities and Exchange Commission (the “Commission”) on March 20, 2018.
As discussed with the staff of the Division of Corporation Finance (the “Staff”) of the Commission, for the convenience of the Staff, we are also sending, by hand, five copies of Amendment No. 1 in paper format, marked to show changes from the third draft registration statement on Form S-1 as confidentially submitted on March 6, 2018.
If the Staff has any questions or requires any additional information, please contact Sandra L. Flow or Alejandro Canelas Fernandez at Cleary Gottlieb Steen & Hamilton LLP at (212)-225-2000.
| Very truly yours, |
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| /s/ Quinn J. Coburn |
| Quinn J. Coburn |
| 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