BOISE PAPER HOLDINGS, L.L.C.
BOISE CO-ISSUER COMPANY
1111 West Jefferson Street, Suite 200
Boise, Idaho 83702
June 11, 2010
VIA EDGAR AND FACSIMILE TRANSMISSION
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: John Reynolds,
Assistant Director
| RE: | Acceleration request |
Boise Paper Holdings, L.L.C., Boise Co-Issuer Company and each
of the guarantors set forth on the signature page hereto
Registration Statement on Form S-4 (File Nos. 333-166926 and
333-166926-01 through 333-166926-11)
Dear Mr. Reynolds:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Boise Paper Holdings, L.L.C., Boise Co-Issuer Company and each of the guarantors set forth on the signature page hereto (the “Registrants”) hereby request that the effectiveness of the above-referenced Registration Statement on Form S-4 be accelerated so that it may become effective by 4:00 p.m., Washington, D.C. time, on Monday, June 14, 2010, or as soon as practicable thereafter.
In connection with this request, the Registrants acknowledge that:
| (a) | should the United States Securities and Exchange Commission (the “Commission”) or its staff, acting pursuant to delegated authority, declare the above-referenced Registration Statement effective, it does not foreclose the Commission from taking any action with respect to such Registration Statement; |
| (b) | the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the above-referenced Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure contained in such Registration Statement; and |
John Reynolds
United States Securities and Exchange Commission
Division of Corporation Finance
June 11, 2010
Page 2
| (c) | the Registrants may not assert staff comments or 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. |
We respectfully request that we be notified of such effectiveness by a telephone call to Margaret A. Brown of Skadden, Arps, Slate, Meagher & Flom LLP at (617) 573-4815 and that such effectiveness also be confirmed in writing.
Very truly yours, | ||||||
BOISE PAPER HOLDINGS, L.L.C. BOISE CO-ISSUER COMPANY BZ INTERMEDIATE HOLDINGS LLC | ||||||
BOISE PACKAGING & NEWSPRINT, L.L.C. BOISE WHITE PAPER, L.L.C. BOISE CASCADE TRANSPORTATION HOLDINGS CORP. | ||||||
BOISE WHITE PAPER SALES CORP. BOISE WHITE PAPER HOLDINGS CORP. BEMIS CORPORATION | ||||||
B C T INC. INTERNATIONAL FALLS POWER COMPANY MINNESOTA, DAKOTA & WESTERN RAILWAY COMPANY | ||||||
| By: | /S/ KAREN E. GOWLAND | |||||
| Name: | Karen E. Gowland | |||||
| Title: | Vice President, General Counsel and Secretary | |||||
| cc: | Margaret A. Brown, Esq. |
Skadden, Arps, Slate, Meagher & Flom LLP
