June 28, 2010
VIA FACSIMILE AND EDGAR
United States Securities and Exchange Commission
Washington, D.C. 20549
Attention: Erin Wilson
Mail Stop 3561
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| | | Re: | | Graphic Packaging Holding Company |
| | | | | Graphic Packaging International, Inc. |
| | | | | Graphic Packaging Corporation |
| | | | | Bluegrass Container Canada Holdings, LLC |
| | | | | Bluegrass Flexible Packaging Company, LLC |
| | | | | Bluegrass Labels Company, LLC |
| | | | | Bluegrass Multiwall Bag Company, LLC |
| | | | | Field Container Queretaro (USA), L.L.C. |
| | | | | Graphic Packaging Flexible Holdings, LLC |
| | | | | Handschy Holdings, LLC |
| | | | | Handschy Industries, LLC |
| | | | | Riverdale Industries, LLC |
| | | Amendment No. 1 to Registration Statement on Form S-3 |
| | | Filed on May 25, 2010 |
| | | File No. 333-166324 |
Dear Ms. Wilson:
On May 25, 2010, Graphic Packaging Holding Company (the “Company”), Graphic Packaging International, Inc. and the additional registrants listed on Exhibit A (collectively with the Company, the “Registrants”) filed via EDGAR Amendment No. 1 to the above-referenced Registration Statement on Form S-3 (“Amendment No. 1 to the Registration Statement”).
The Registrants acknowledge that (i) should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, such declaration does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or the staff of the Commission, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full
responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Registrants may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| | | | | |
| | Sincerely,
GRAPHIC PACKAGING HOLDING COMPANY
GRAPHIC PACKAGING INTERNATIONAL, INC.
GRAPHIC PACKAGING CORPORATION
BLUEGRASS CONTAINER CANADA HOLDINGS, LLC
BLUEGRASS FLEXIBLE PACKAGING COMPANY, LLC
BLUEGRASS LABELS COMPANY, LLC
BLUEGRASS MULTIWALL BAG COMPANY, LLC
FIELD CONTAINER QUERETARO (USA), L.L.C.
GRAPHIC PACKAGING FLEXIBLE HOLDINGS, LLC
HANDSCHY HOLDINGS, LLC
HANDSCHY INDUSTRIES, LLC
RIVERDALE INDUSTRIES, LLC
| |
| | By: | /s/ Laura Lynn Smith | |
| | | Laura Lynn Smith | |
| | | Assistant Secretary | |
| |
cc: Justin R. Howard
EXHIBIT A
Graphic Packaging Corporation
Bluegrass Container Canada Holdings, LLC
Bluegrass Flexible Packaging Company, LLC
Bluegrass Labels Company, LLC
Bluegrass Multiwall Bag Company, LLC
Field Container Queretaro (USA), L.L.C.
Graphic Packaging Flexible Holdings, LLC
Handschy Holdings, LLC
Handschy Industries, LLC
Riverdale Industries, LLC
