March 4, 2019
BY EDGAR
Tim Buchmiller
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 Filed on Form S-1
File No. 333-230056
Ladies and Gentlemen:
In connection with the above-captioned Registration Statement, we wish to advise that the number of Preliminary Prospectuses dated March 4, 2019 that will be furnished to 6 prospective underwriters and distributed to underwriters, institutional investors, individuals, dealers, brokers and others on the date hereof will be approximately 1,000.
We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:40 p.m., Eastern Time, on March 6, 2019 or as soon thereafter as practicable.
[Signature Pages Follow]
Very truly yours,
J.P. MORGAN SECURITIES LLC
CREDIT SUISSE SECURITIES (USA) LLC
As Representatives of the several Underwriters
| J.P. MORGAN SECURITIES LLC |
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| /s/ Jin Izawa |
| Name: Jin Izawa |
| Title: Vice President |
[Signature Page to Underwriters’ Acceleration Request]
| CREDIT SUISSE SECURITIES (USA) LLC |
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| /s/ Andrew Frame |
| Name: Andrew Frame |
| Title: Director |
[Signature Page to Underwriters’ Acceleration Request]