1521 Concord Pike Brandywine West, Suite 301 Wilmington, DE 19803 |
(302) 778-8208 | |||
Corrado F. De Gasperis | Facsimile (302) 778-8209 | ||
Vice President, Chief Financial Officer & Chief Information Officer | c.degasperis@graftech.com |
May 11, 2004
Securities and Exchange
Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: GrafTech
International Ltd.
Application to Withdraw Post-Effective Amendment No. 3 to Registration
Statement on Form S-3
(Registration No. 333-82417)
Ladies and Gentlemen:
Pursuant to Rule 477(a) promulgated under the Securities Act of 1933, as amended (the Securities Act), GrafTech International Ltd., a Delaware corporation (the Company), hereby requests that the Securities and Exchange Commission (the Commission) issue an order granting the immediate withdrawal of the Companys Post-Effective Amendment No. 3 to Registration Statement on Form S-3 (No. 333-82417) filed on April 21, 2004 (the Amendment) because it was filed with the incorrect EDGAR tags. No securities were sold in connection with the Amendment.
The Company also requests, in accordance with Rule 457(p) under the Securities Act, that all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use for the Companys account.
If you have any questions regarding the foregoing application for withdrawal, please contact Randi-Jean G. Hedin at Kelley Drye & Warren LLP, at (203) 351-8107.
Sincerely GRAFTCH INTERNATIONAL LTD. By:/s/ Corrado F. De Gasperis Name: Corrado F. De Gasperis Title: Vice President, Chief Financial Officer & Chief Information Officer |