VIA EDGAR AND FACSIMILE
November 10, 2008
David R. Humphrey
Branch Chief
Mail Stop 3561
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
| Re: | American Vanguard Corporation |
Form 10-K for the Year Ended December 31, 2007
Filed March 17, 2008
File Number: 001-13795
Dear Mr. Humphrey:
Enclosed herewith is the Form 10-Q of American Vanguard Corporation (the “Company”) for the period ended September 30, 2008 (the “Q3 10-Q”). The Company has attempted to incorporate into the Q3 10-Q the changes recommended by the Commission in its letters dated July 15, 2008 and August 26, 2008. We are concurrently filing the Q3 10-Q with the Commission through the public EDGAR filing portal.
Further, 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 a proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
American Vanguard Corporation
4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660
We appreciate your assistance in our compliance with applicable disclosure requirements and in enhancing our overall disclosure. Please do not hesitate to contact me at (949) 221-6140 if you have further questions or comments on this matter.
| Sincerely, |
| AMERICAN VANGUARD CORPORATION |
| /s/ James A. Barry |
| James A. Barry |
| Chief Administrative Officer, Treasurer and Assistant Secretary |
| cc: | Juan Migone (SEC Staff – fax 202.772.9202) |
Lyn Shenk (SEC Staff – fax 202.772.9202)
American Vanguard Corporation
4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660