March 22, 2017
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-7010
| Re: | Request for Acceleration of Effectiveness |
Westlake Chemical Corporation
Registration Statement on Form S-4
Filed March 13, 2017
File No. 333-216662
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Westlake Chemical Corporation, on behalf of itself and the other registrants thereof (collectively, the “Registrants”), hereby requests that the effectiveness of the Registration Statement on Form S-4 (File No. 333-216662) (the “Registration Statement”) be accelerated so that the Registration Statement will become effective on March 27, 2017, at 10:00 a.m. Eastern time, or as soon thereafter as practicable.
[Signature on following page]
| Very truly yours, | ||||||||||
| WESTLAKE CHEMICAL CORPORATION | ||||||||||
| By: | /s/ L. Benjamin Ederington | |||||||||
| Name: | L. Benjamin Ederington | |||||||||
| Title: | Vice President, General Counsel, Chief Administrative Officer and Corporate Secretary | |||||||||
| GEISMAR HOLDINGS, INC. | WPT LLC | |||
| GVGP, INC. | BY WESTLAKE CHEMICAL INVESTMENTS, INC., | |||
| WESTLAKE CHEMICAL INVESTMENTS, INC. | ITS MANAGER | |||
| WESTLAKE GEISMAR POWER COMPANY LLC | WESTLAKE PETROCHEMICALS LLC | |||
BY WESTLAKE VINYLS COMPANY LP, | BY WESTLAKE CHEMICAL INVESTMENTS, INC., | |||
ITS MANAGER | ITS MANAGER | |||
BY GVGP, INC. | WESTECH BUILDING PRODUCTS (EVANSVILLE) LLC | |||
ITS GENERAL PARTNER | BY WESTECH BUILDING PRODUCTS, INC., | |||
| WESTLAKE LONGVIEW CORPORATION | ITS MANAGER | |||
| WESTLAKE MANAGEMENT SERVICES, INC. | NORTH AMERICAN SPECIALTY PRODUCTS LLC | |||
| WESTLAKE NG I CORPORATION | BY NORTH AMERICAN PIPE CORPORATION, | |||
| WESTLAKE OLEFINS CORPORATION | ITS MANAGER | |||
| WESTLAKE PIPELINE INVESTMENTS LLC | LAGOON LLC | |||
BY WESTLAKE CHEMICAL INVESTMENTS, INC., | BY WESTLAKE CHEMICAL CORPORATION, | |||
ITS MANAGER | ITS MANAGER | |||
| WESTLAKE POLYMERS LLC | AXIALL CORPORATION | |||
BY WESTLAKE CHEMICAL INVESTMENTS, INC., | AXIALL HOLDCO, INC. | |||
ITS MANAGER | AXIALL NOTECO, INC. | |||
| WESTLAKE PVC CORPORATION | AXIALL OHIO, INC. | |||
| WESTLAKE RESOURCES CORPORATION | AXIALL, LLC | |||
| WESTLAKE STYRENE LLC | EAGLE HOLDCO 3 LLC | |||
BY WESTLAKE CHEMICAL INVESTMENTS, INC., | EAGLE NATRIUM LLC | |||
ITS MANAGER | EAGLE PIPELINE, INC. | |||
| WESTLAKE SUPPLY AND TRADING COMPANY | EAGLE SPINCO INC. | |||
| WESTLAKE VINYL CORPORATION | EAGLE US 2 LLC | |||
| WESTLAKE VINYLS COMPANY LP | GEORGIA GULF LAKE CHARLES, LLC | |||
BY GVGP, INC. | PHH MONOMERS, LLC | |||
ITS GENERAL PARTNER | PLASTIC TRENDS, INC. | |||
| WESTLAKE VINYLS, INC. | ROME DELAWARE CORPORATION | |||
| ROYALS BUILDING PRODUCTS (USA) INC. | ||||
| ROYAL PLASTICS GROUP (U.S.A.) LIMITED |
| By: | /s/ L. Benjamin Ederington | |||||||||
| Name: | L. Benjamin Ederington | |||||||||
| Title: | General Counsel, Chief Administrative Officer and Secretary | |||||||||
| cc: | Julia Feng | |
| Westlake Chemical Corporation | ||
| Timothy Taylor | ||
| Baker Botts L.L.P. | ||
Signature Page to Acceleration Request