WOLVERINE TUBE, INC.
April 20, 2007
Ms. Jennifer Hardy
Branch Chief
Division of Corporate Finance
Securities and Exchange Commission
Washington, D.C. 20549-7010
| Re: | Wolverine Tube, Inc. Preliminary Proxy Statement on Schedule 14A Filed April 3, 2007 SEC File No. 001-12164 |
Dear Ms. Hardy:
This letter is submitted by Wolverine Tube, Inc. respecting the above-referenced matter. The Company acknowledges the following:
1. The Company is responsible for the adequacy and accuracy of the disclosure contained in the proxy statement for its 2007 annual meeting;
2. The Company understands that staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking action with respect to the proxy statement; and
3. 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.
Sincerely,
/s/ James E. Deason
James E. Deason
Senior Vice President, Chief Financial Officer and Secretary