June 1, 2005

Stephen Wallace, Esq.
Vice President, General Counsel and Corporate Secretary
Westlake Chemical Corporation
2801 Post Oak Boulevard, Suite 600
Houston, TX 77056

Re:	Westlake Chemical Corporation
	Registration Statement on Form S-3
	Filed on May 3, 2005
	File No. 333-124581

Dear Mr. Wallace:

      We have limited our review of your filing to those issues we
have addressed on our comments.  Where indicated, we think you
should
revise your documents in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects.  We welcome
any
questions you may have about our comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

General

1. Please confirm that the additional registrants are only
guarantors
of debt securities.

2. At the time the company requests acceleration of this
registration
statement, the company should state that it has no present intent
to
make the first offering of securities promptly, and therefore will
be
making the offering on a delayed basis rather than in reliance on
Rule
430A.  Alternatively, the company should file a pre-effective
amendment to include all of the information about the securities
to be
offered, plan of distribution, a clean legality opinion and, if
applicable, an underwriting agreement with regard to any
securities to
be offered promptly, including in reliance on Rule 430A.

Use of Proceeds, page 10

3. Confirm to us that your takedown supplements will disclose the
amount and terms of debt you may pay off with proceeds from the
sale
of the securities.

Description of Warrants, page 26

4. We advise you that warrants may not be issued for "other
securities" that have not been registered under this registration
statement unless the warrants exercisable for such other
securities
are not legally exercisable immediately or within one year of the
date
of sale of the warrant.  All of the underlying classes of
securities
to which the warrants relate must be identified in the
registration
statement.

Plan of Distribution, page 27

5. You refer to the remarketing of the securities. Please note
that,
depending upon the level of involvement by the issuer (or its
affiliates) in the "reset" mechanism, any offers or sales pursuant
to
that "reset" mechanism may require registration under the
Securities
Act of 1933. If the issuer would prefer that the staff express its
views on this issue at the present time, please supplementally
provide
information about the procedures that will be used and the
participants in the remarketing, including the role of the company
or
its affiliates.

Legal Opinion

6. Please confirm to us that you will file a clean opinion, either
in
post-effective amendment or in a Form 8-K, for each takedown.

Closing Comments

	As appropriate, please amend your filing in response to these
comments.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have
made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal
securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in connection with our review of your
filing or
in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please contact Brigitte Lippmann at (202) 551-3713 or Lesli
Sheppard at (202) 551-3708 with any questions. In this regard,
please
do not hesitate to contact the undersigned at (202) 551-3760.

Sincerely,



Pamela A. Long
Assistant Director

cc:	J. David Kirkland, Jr., Esq.
	Baker Botts L.L.P.
	910 Louisiana Street
	Houston, TX 77002-4995

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Stephen Wallace, Esq.
Westlake Chemical Corporation
June 1, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE