November 30, 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
	Amendment No. 1 to Registration Statement on Form S-3
	Filed on November 23, 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. We note your response to prior comment 2. Please let us know if
your plans have changed and you have a present intent to make the
first offering of securities promptly.

Registration Statement Cover Page

2. We note your new disclosure at footnote 5 to the calculation of
registration fee table.  Please confirm that as securities are
offered and sold, you will count them against the dollar amount of
the securities remaining on this registration statement.

Prospectus Cover Page

3. Please disclose that your affiliates are the selling
stockholders.

Private Sales, page 29

4. Please revise to indicate the number of shares which qualify
for
sale pursuant to Rule 144.

Selling Stockholder, page 27

5. Supplementally advise us whether TTWF LP is a broker-dealer or
an
affiliate of a broker-dealer.

6. Please describe how TTWF LP acquired the securities.

7. Please revise this section to indicate that the selling
stockholders may be underwriters with respect to the shares that
they
are offering for resale.

Registration Rights Agreement, page 27

8. Please file the registration rights agreement as an exhibit to
your revised registration statement.

Item 17. Undertakings

9. Please revise to conform to the new version of the Item 512(a)
undertaking.

Exhibit 5.1

10. Please have counsel revise to opine that the warrants will be
binding obligations of the company, enforceable against the
company
in accordance with their terms.

11. Please have counsel revise the first sentence of the last
paragraph of the opinion to delete "matters of the contract law".
Counsel must opine on New York law, including New York contract
law.

12. Also, please confirm that by the General Corporation Law of
the
State of Delaware, you mean all Statutes, Supreme Court and
Chancery
Court Decisions and provisions of the Delaware Constitution that
affect the interpretation of the General Corporation Law.

	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
November 30, 2005
Page 1



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

         DIVISION OF
CORPORATION FINANCE