VERSO PAPER CORP.
VERSO PAPER HOLDINGS LLC
VERSO PAPER INC.
6775 Lenox Center Court, Suite 400
Memphis, TN 38115-4436
July 10, 2014
Via EDGAR Submission
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Karina V. Dorin |
| Re: | Verso Paper Corp., Verso Paper Holdings LLC and Verso Paper Inc. |
| Registration Statement on Form S-4 |
| File No. 333-193794 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), Verso Paper Corp., a Delaware corporation, Verso Paper Holdings LLC, a Delaware limited liability company, and Verso Paper Inc., a Delaware corporation (collectively, the “Companies”), hereby request acceleration of the effective date of the Registration Statement on Form S-4 (File No. 333-193794), as amended, with respect to themselves and the subsidiaries specified therein (the “Registration Statement”) to 2:00 p.m., Eastern Time, on July 11, 2014, or as soon thereafter as practicable. The Companies hereby acknowledge their responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement. In addition, the Companies acknowledge that:
| • | should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Companies from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Companies 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. |
Please contact Joshua N. Korff or Michael Kim of Kirkland & Ellis LLP, special counsel to the Companies, at (212) 446-4943 or (212) 446-4746, respectively, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
| Sincerely, | ||
Verso Paper Corp. Verso Paper Holdings LLC Verso Paper Inc. | ||
| By: | /s/ David J. Paterson | |
| David J. Paterson | ||
| President and Chief Executive Officer | ||
| cc: | Joshua N. Korff, Esq. |
| Michael Kim, Esq. |
| Kirkland & Ellis LLP |
| Peter H. Kesser, Esq. |
| Verso Paper Corp. |
