o, 2004

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

         Re: Crompton Corporation  - Registration Statement on Form S-4

Ladies and Gentlemen:

In connection with the Registration Statement on Form S-4 (the "Registration
Statement") of Crompton Corporation (the "Company"), the Company hereby makes
the following representations to the Commission:

         (1)      the Company is registering under the Securities Act of 1933,
                  as amended (the "Securities Act"), its exchange 9-7/8% Senior
                  Notes due 2012 and related subsidiary guarantees, and its
                  exchange Senior Floating Rate Notes due 2010 and related
                  subsidiary guarantees (collectively, the "exchange notes") to
                  be offered in the exchange offer (the "exchange offer") in
                  reliance on the staff's the position in SHEARMAN & STERLING
                  (available July 2, 1993), MORGAN STANLEY CO. INCORPORATED
                  (available June 5, 1991) and EXXON CAPITAL HOLDING CORPORATION
                  (available May 13, 1988) (the "Exxon Capital Letter"); and

         (2)      the Company has not entered into any arrangement or
                  understanding with any person to distribute the exchange notes
                  to be received in the exchange offer and, to the best of the
                  Company's information and belief, each person participating in
                  the exchange offer is acquiring the exchange notes in the
                  ordinary course of its business and has no arrangement or
                  understanding with any person to participate in the
                  distribution of the exchange notes to be received in the
                  exchange offer. In this regard, the Company will make each
                  person participating in the exchange offer aware (through the
                  exchange offer prospectus or otherwise) that (A) if the
                  exchange offer is being registered for the purpose of
                  secondary resales, any securityholder using the exchange offer
                  to participate in a distribution of the exchange notes (i)
                  could not rely on the staff position enunciated in the Exxon
                  Capital letter or similar letters and (ii) must comply with
                  registration and prospectus delivery requirements of the
                  Securities Act in connection with a secondary resale
                  transaction and (B) that any broker-dealer who holds the
                  9-7/8% Senior Notes due 2012 and related subsidiary
                  guarantees, and the Senior Floating Rate Notes due 2010 and
                  related subsidiary guarantees (collectively, the "initial
                  notes") for its own account as a result of market-making
                  activities or other trading activities, and who receives
                  exchange notes in exchange for such initial notes pursuant to
                  the exchange offer, may be a statutory underwriter and must
                  deliver a prospectus meeting the requirements of the
                  Securities Act in connection with any resale of the exchange
                  notes. The Company acknowledges that a secondary resale
                  transaction as described in clause A above should be covered
                  by an effective registration statement containing (except in
                  the case of sales by a broker-dealer of exchange notes
                  received in exchange for initial notes acquired for its own
                  account as a result of market-making or other trading
                  activities) the selling securityholder information required by
                  Item 507 of Regulation S-K under the Securities Act.

Very truly yours,



_____________________
Karen R. Osar
Executive Vice President and Chief Financial Officer