September 15, 2005


Ms. Annie S. Veerman
Chief Financial Officer, Lucite International Group Holdings Ltd
Queens Gate
15-17 Queens Terrace
Southhampton  S014 3BP
United Kingdom

Re:	Lucite International Group Holdings Ltd
Form 20-F for the fiscal year ended December 31, 2004
Form 6-K for the period ended June 30, 2005
      File No. 333-12714

Dear Ms. Veerman:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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 or may not 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.

Form 20-F for the fiscal year ended December 31, 2004

Selected Financial Data - Exchange Rate Information, page 8
1. In future filings please disclose all exchange rates as
required by
paragraph 5B of Item 301 of Regulation S-K including a history of
exchange rates for the five most recent years setting forth the
rates
for period end, the average rates, and the range of high and low
rates
for each year.

Note 3 - Segmental Reporting, page F-12
2. Based on the description of your business beginning on page 14,
it
appears that you may have multiple operating segments as defined
by
paragraph 10 of SFAS 131 that you have aggregated into one
reportable
segment.  Please tell us how you determined that you have two
reportable segments.  If you have aggregated operating segments,
tell
us how you determined the aggregation to be appropriate based on
the
guidance provided in paragraph 17 of SFAS 131.  In addition,
revise
future filings to provide product-line disclosures as required by
paragraph 37 of SFAS 131 or tell us why they are not required.

Form 6-K for the period ended June 30, 2005

Note 6 - EBITDA, page 8

3. We note that you are presenting EBITDA as an operating
performance
measure.  It also appears that you are presenting EBITDA as a
liquidity measure from your statement that it is accepted as a
financial indicator of the ability to incur and service debt.  As
such, please revise your disclosure to provide the following
information, as required by Item 10(e) of Regulation S-K and
questions
8 and 12 of the SEC "Frequently Asked Questions Regarding the Use
of
Non-GAAP Financial Measures:"
* Performance measure:  Expand your discussion of the limitations
of
EBITDA to address how the exclusion of each item materially limits
the
usefulness of EBITDA.  For instance you might expand your
disclosures,
in part, to address the limitations of EBITDA as a performance
measure
by providing the following information:
o It does not include interest expense.  Because we have borrowed
money in order to finance our operations, interest expense is a
necessary element of our costs and ability to generate revenue.
Therefore, any measure that excludes interest expense has material
limitations;
o It does not include depreciation and amortization expense.
Because
we use capital assets, depreciation and amortization expense is a
necessary element of our costs and ability to general revenue.
Therefore, any measure that excludes depreciation and amortization
expense has material limitations;
o It does not include taxes.  Because the payment of taxes is a
necessary element of our operations, any measure that excludes tax
expense has material limitations.
* Performance measure:  State how you compensate for the material
limitations of using EBITDA.
* Performance measure: State the economic substance behind your
decision to use such a measure.
* Performance measure: Please provide substantive reasons why
management believes EBITDA provides useful information to
investors.
* Liquidity measure: Reconcile EBITDA to cash flows from operating
activities, as the most comparable liquidity GAAP financial
measure,
in addition to reconciling to net income.
* Liquidity measure: Present the three major categories of the
statement of cash flows with equal or greater prominence.
      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please provide us with a supplemental response
letter that keys your responses to our comments and provides any
requested supplemental information.  Detailed letters greatly
facilitate our review.  Please file your supplemental response on
EDGAR as a correspondence file.  Please understand that we may
have
additional comments after reviewing your responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities and
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment 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.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* 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 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 our review of your filing or in response
to
our comments on your filing.

If you have any questions regarding these comments, please direct
them
to Mindy Hooker, Staff Accountant, at (202) 551-3732 or to the
undersigned at (202) 551-3768.

Sincerely,


John Cash
Branch Chief
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Annie Veerman
Lucite International Group Holdings Ltd
September 15, 2005
Page 3


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE