[RPM LETTERHEAD]




                                 March 21, 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 23, 2005, or as soon as practicable thereafter. The Company
withdraws its earlier acceleration request filed with the Commission on March
17, 2005.

                  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






Ms. Pamela A. Long
Division of Corporate Finance
Securities and Exchange Commission
March 21, 2005
Page 2


                               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