Calumet Specialty Products Partners, L.P.
Calumet Finance Corp.
2780 Waterfront Pkwy E. Drive, Suite 200
Indianapolis, Indiana 46214
June 25, 2013
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Karina V. Dorin
| Re: | Calumet Specialty Products Partners, L.P., Calumet Finance Corp. and co-registrants (the “Registrants”) |
Request for Acceleration of Effectiveness
Registration Statement on Form S-4 (File No. 333-185262) (the “Registration Statement”)
Ladies and Gentlemen:
Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of 1933, as amended, the Registrants hereby request that the effectiveness of the Registration Statement be accelerated so that the Registration Statement will become effective on Thursday, June 27, 2013 at 4:00 p.m., Eastern Time, or as soon thereafter as practicable.
The Registrants hereby acknowledge that the disclosure in the Registration Statement is the responsibility of the Registrants. The Registrants hereby acknowledge that:
| • | should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
| • | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and |
| • | the Registrants may not assert Staff comments and 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. |
United States Securities and Exchange Commission
June 25, 2013
Please call Gillian A. Hobson of Vinson & Elkins L.L.P., the Registrants’ outside legal counsel, at (713) 758-3747 with any questions regarding this request for acceleration.
| Sincerely, | ||||
| CALUMET SPECIALTY PRODUCTS PARTNERS, L.P. | ||||
| By: | Calumet GP, LLC, its General Partner | |||
| By: | /s/ R. Patrick Murray, II | |||
| R. Patrick Murray, II | ||||
Senior Vice President, Chief Financial Officer and Secretary of Calumet GP, LLC | ||||
| CALUMET FINANCE CORP. | ||||
| CALUMET OPERATING, LLC | ||||
| CALUMET LP GP, LLC | ||||
| CALUMET NORTH DAKOTA, LLC | ||||
| CALUMET PENRECO, LLC | ||||
| TRUSOUTH OIL, LLC | ||||
| CALUMET SHREVEPORT, LLC | ||||
| CALUMET SHREVEPORT LUBRICANTS & WAXES, LLC | ||||
| CALUMET SHREVEPORT FUELS, LLC | ||||
| CALUMET SAN ANTONIO REFINING, LLC | ||||
| CALUMET SALES COMPANY INCORPORATED | ||||
| S&S INTERNATIONAL MINING ENTERPRISES, INC. | ||||
| CALUMET SUPERIOR, LLC | ||||
| CALUMET MISSOURI, LLC | ||||
| CALUMET MONTANA REFINING, LLC | ||||
| CALUMET RP I, LLC | ||||
| CALUMET RP II, LLC | ||||
| CALUMET RP III, LLC | ||||
| CALUMET RP IV, LLC | ||||
| ROYAL PURPLE, LLC | ||||
| By: | /s/ R. Patrick Murray, II | |||
| R. Patrick Murray, II | ||||
| Senior Vice President, Chief Financial Officer and Secretary | ||||
| CALUMET LUBRICANTS CO., LIMITED PARTNERSHIP | ||||
| By: | Calumet LP GP, LLC, its General Partner | |||
| By: | /s/ R. Patrick Murray, II | |||
| R. Patrick Murray, II | ||||
Senior Vice President, Chief Financial Officer and Secretary of Calumet LP GP, LLC | ||||
| cc: | Gillian A. Hobson, Esq. |
Vinson & Elkins L.L.P.
