KRONOS INTERNATIONAL, INC.
Three Lincoln Center
5430 LBJ Freeway
Suite 1700
Dallas, Texas 75240-2697
July 8, 2005
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
RE: Kronos International, Inc.
Registration Statement on Form S-4 (Registration No. 333-123680)
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended, Kronos International, Inc. (the "Company")
hereby requests that the effectiveness of the above-referenced Registration
Statement be accelerated to 1:00 p.m. (Washington, D.C. time) on July 12, 2005,
or as soon thereafter as practicable.
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 this action as defense in any proceeding
initiated by the Commission or any person under federal securities
laws of the United States.
Very truly yours,
KRONOS INTERNATIONAL, INC.
By: /s/ Robert D. Graham
--------------------
Robert D. Graham
Vice President