Jeffrey T. Haughey
Partner
4801 Main Street, Suite 1000
Kansas City, MO 64112
Direct: 816.983.8146
Fax: 816.983.8080
jeff.haughey@huschblackwell.com
February 3, 2012
VIA EDGAR
Mr. Jay Ingram
Legal Branch Chief
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 7010
Washington, DC 20549
| Re: | WireCo WorldGroup Inc. |
| Amendment No. 4 to Form S-4 |
| Filed January 30, 2012 |
| File No. 333-174896 |
Dear Mr. Ingram:
We have set forth below the response of WireCo WorldGroup Inc. (“WireCo” or the “Company”) and its Co-Registrants to the comments of the staff of the Securities and Exchange Commission (the “Staff”), received by telephone on February 2, 2012. The Company is concurrently filing via EDGAR Amendment No. 5 to the Registration Statement on Form S-4 (the “Amendment No. 5”). Amendment No. 5 reflects the Company’s response to the Staff’s comments.
General
Response: The prospectus and footnote disclosures have been revised as requested to refer to the Subsidiary Guarantees as being “full and unconditional,” subject to customary release provisions.
Mr. Jay Ingram
Legal Branch Chief
Division of Corporation Finance
February 3, 2012
Page 2
If you have questions or comments concerning the matters discussed above, please call the undersigned at 816-983-8146 or Steve Carman at 816-983-8153.
Respectfully submitted,
/s/ Jeffrey T. Haughey
Jeffrey T. Haughey
