[SCHULTE ROTH & ZABEL LLP LOGO] 919 Third Avenue New York, NY 10022 (212) 756-2000 fax (212) 593-5955 www.srz.com November 1, 2006 VIA EDGAR - --------- Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Ms. Brigitte Lippmann Re: RathGibson, Inc. Registration Statement on Form S-4 ("Registration Statement") Filed June 9, 2006 File No. 333-134875 Dear Ms. Lippmann: Pursuant to Rule 461(a) under the Securities Act of 1933, as amended (the "Securities Act"), the undersigned hereby respectfully requests that the effective date for the above-referenced Registration Statement on Form S-4 (File No. 333-134875) fled with the Securities and Exchange Commission on June 9, 2006, as amended, be accelerated so that it will be declared effective at 4:00 p.m., New York City time, on November 1, 2006, or as soon as practicable thereafter. Please notify the undersigned at (212) 756-2497 as soon as possible as to the time the Registration Statement has been declared effective pursuant to this acceleration request. Very truly yours, /s/ James Nicoll James Nicoll Ms. Brigitte Lippmann November 1, 2006 Page 2 CC: Barry Nuss, RathGibson, Inc. Michael Littenberg, Schulte Roth & Zabel LLP
