CLEARWATER PAPER CORPORATION
601 West Riverside, Suite 1100
Spokane, Washington 99201
October 7, 2010
VIA EDGAR AND UPS
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.W., Mail Stop 3561
Washington, D.C. 20549
Attention: Blaise Rhodes, Division of Corporation Finance
| Re: | Clearwater Paper Corporation |
| Form 10-K |
| Filed February 26, 2010 |
| File No. 001-34146 |
Dear Mr. Rhodes:
This letter is in response to your follow-up comment letter dated September 17, 2010 concerning your review of the Clearwater Paper Corporation Form 10-K for the year ended December 31, 2009.
Form 10-K for Fiscal Year Ended December 31, 2009
Financial Statements and Supplemental Data
Statements of Cash Flows, page 39
| 1. | We read your response to our prior comment one. However, it appears that the proceeds from the issuance of your senior unsecured notes and the amount utilized to repay your credit sensitive debentures should be presented on a gross basis. This type of presentation would enable the investor to better understand the nature of your cash flows from financing activities as these transactions do not appear to have characteristics which support net presentation. Please confirm that you will revise your statement of cash flows in future Exchange Act filings to present the amounts related to these transactions on a gross basis. Refer to FASB ASC 230-10-45-8 and 230-10-45-14 through 45-15 |
Response:
We will revise our statement of cash flows in future Exchange Act filings to present the amounts related to these transactions on a gross basis.
* * *
U.S. Securities and Exchange Commission
September 7, 2010
Page 2
The Company acknowledges the following:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| • | the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please contact me at (509)-344-5920, or our outside counsel, Justin D. Hovey at Pillsbury Winthrop Shaw Pittman LLP at (415) 983–6117, if you have further questions or comments.
| Very truly yours, |
| /s/ Michael S. Gadd |
Michael S. Gadd Vice President, General Counsel & Corporate Secretary Clearwater Paper Corporation |
| cc: | Blair W. White |
| Justin D. Hovey |
