TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo August 8, 2022 David Ure Chief Financial Officer Mercer International Inc. Suite 1120, 700 West Pender Street Vancouver, British Columbia Canada, V6C 1G8 Re: Mercer International Inc. Registration Statement on Form S-3 Filed August 2, 2022 File No. 333-266466 Dear Mr. Ure: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Gregory Herbers at 202-551-8028 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Rod Talaifar