Aleris International, Inc. 25825 Science Park Drive, Suite 400 Beachwood, Ohio 44122-7392 Tel: 216-910-3573 Fax: 216-910-3654 pauline.moorman@aleris.com Pauline L. Moorman Vice President, Legal |  |
February 5, 2015
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Aleris Corporation | ||
| Registration Statement on Form S-1 | |||
| Filed April 26, 2011 | |||
| File No. 333-173721 | |||
Ladies and Gentlemen:
On April 26, 2011, Aleris Corporation, a Delaware corporation (the “Company”), filed a Registration Statement on Form S-1 (File No. 333-173721) (together with the exhibits and amendments thereto, the “Registration Statement”) under the Securities Act of 1933, as amended (the “Securities Act”), with the Securities and Exchange Commission (the “Commission”). Pursuant to Rule 477 under the Securities Act, the Company hereby requests that the Commission consent to the withdrawal of the Registration Statement effective as of the date hereof or at the earliest practicable date hereafter. The Company submits this request for withdrawal as it does not intend to pursue the initial public offering contemplated by the Registration Statement at this time. The Registration Statement has not been declared effective by the Commission and no securities have been issued or sold under the Registration Statement. Therefore, the Company believes that the withdrawal of the Registration Statement is consistent with the public interest and the protection of investors, as contemplated by Rule 477(a) under the Securities Act.
The Company acknowledges that no refund will be made for fees paid to the Commission in connection with filing of the Registration Statement. However, the Company respectfully requests that, in accordance with Rule 457(p) under the Securities Act, all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use.
If you have any questions with respect to this matter, please call Daniel J. Bursky or Andrew B. Barkan of Fried, Frank, Harris, Shriver & Jacobson LLP at (212) 859-8428 or (212) 859-8468, respectively, or the undersigned at (216) 910-3573.
| Very truly yours, | |||
| ALERIS CORPORATION | |||
| By: | /s/ | Pauline L. Moorman | |
| Name: | Pauline L. Moorman | ||
| Title: | Vice President, Legal | ||