[RPM LETTERHEAD]



                                 March 17, 2005



Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Attention:        Ms. Pamela A. Long
                  Division of Corporate Finance

                  Re:      RPM International Inc.
                           Registration Statement on Form S-4
                           File No. 333-120536

Dear Ms. Long:

     RPM International Inc. (the "Company") hereby requests, pursuant to Rule
461 under the Securities Act of 1933, as amended, that the effective date of the
above-referenced Registration Statement be accelerated to 4:30 p.m. on March 21,
2005, or as soon as practicable thereafter.

     The Company acknowledges that:

          o    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;

          o    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

          o    the Company may not assert staff comments and the declaration of
               effectiveness as a defense in any proceeding initiated by the
               Commission or any person under the federal securities laws of the
               United States.


                                             Very truly yours,

                                             RPM International Inc.

                                             /s/ P. Kelly Tompkins

                                             P. Kelly Tompkins
                                             Senior Vice President,
                                             General Counsel and Secretary