0001193125-12-208911.txt : 20120605 0001193125-12-208911.hdr.sgml : 20120605 20120503171828 ACCESSION NUMBER: 0001193125-12-208911 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120503 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MOMENTIVE SPECIALTY CHEMICALS INC. CENTRAL INDEX KEY: 0000013239 STANDARD INDUSTRIAL CLASSIFICATION: PLASTICS, MATERIALS, SYNTH RESINS & NONVULCAN ELASTOMERS [2821] IRS NUMBER: 130511250 STATE OF INCORPORATION: NJ FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 180 EAST BROAD ST STREET 2: 26TH FLOOR CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: 6142254000 MAIL ADDRESS: STREET 1: 180 EAST BROAD ST STREET 2: 26TH FLR CITY: COLUMBUS STATE: OH ZIP: 43215 FORMER COMPANY: FORMER CONFORMED NAME: HEXION SPECIALTY CHEMICALS, INC. DATE OF NAME CHANGE: 20050603 FORMER COMPANY: FORMER CONFORMED NAME: BORDEN CHEMICAL INC DATE OF NAME CHANGE: 20041117 FORMER COMPANY: FORMER CONFORMED NAME: BORDEN CHEMICAL INC DATE OF NAME CHANGE: 20011203 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LAWTER INTERNATIONAL INC CENTRAL INDEX KEY: 0000058091 STANDARD INDUSTRIAL CLASSIFICATION: PLASTICS, MATERIALS, SYNTH RESINS & NONVULCAN ELASTOMERS [2821] IRS NUMBER: 361370818 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE TERRA WAY STREET 2: 8601 95TH STREET CITY: KENOSHA STATE: WI ZIP: 53412-7716 BUSINESS PHONE: 4149477300 MAIL ADDRESS: STREET 1: ONE TERRA WAY STREET 2: 8601 95TH STREET CITY: KENOSHA STATE: WI ZIP: 53412-7716 FORMER COMPANY: FORMER CONFORMED NAME: LAWTER CHEMICALS INC DATE OF NAME CHANGE: 19810602 FORMER COMPANY: FORMER CONFORMED NAME: KRUMBHAAR CHEMICALS INC DATE OF NAME CHANGE: 19701117 FILER: COMPANY DATA: COMPANY CONFORMED NAME: HSC CAPITAL CORP CENTRAL INDEX KEY: 0001132424 STANDARD INDUSTRIAL CLASSIFICATION: PLASTICS, MATERIALS, SYNTH RESINS & NONVULCAN ELASTOMERS [2821] IRS NUMBER: 760807613 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1600 SMITH STREET SUITE 2418 CITY: HOUSTON STATE: TX ZIP: 77002 BUSINESS PHONE: 8889492502 MAIL ADDRESS: STREET 1: 1600 SMITH STREET SUITE 2416 CITY: HOUSTON STATE: TX ZIP: 77002 FORMER COMPANY: FORMER CONFORMED NAME: RPP CAPITAL CORP DATE OF NAME CHANGE: 20010111 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hexion U.S. Finance Corp. CENTRAL INDEX KEY: 0001315749 STANDARD INDUSTRIAL CLASSIFICATION: PLASTICS, MATERIALS, SYNTH RESINS & NONVULCAN ELASTOMERS [2821] IRS NUMBER: 201362484 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: (614) 225-4000 MAIL ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 FORMER COMPANY: FORMER CONFORMED NAME: Borden U.S. Finance Corp. DATE OF NAME CHANGE: 20050127 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Hexion Nova Scotia Finance, ULC CENTRAL INDEX KEY: 0001315751 IRS NUMBER: 000000000 STATE OF INCORPORATION: A5 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: (614) 225-4000 MAIL ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 FORMER COMPANY: FORMER CONFORMED NAME: Borden Nova Scotia Finance, ULC DATE OF NAME CHANGE: 20050127 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Borden Chemical Foundry LLC CENTRAL INDEX KEY: 0001315752 IRS NUMBER: 311766429 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: (614) 225-4000 MAIL ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 FORMER COMPANY: FORMER CONFORMED NAME: Borden Chemical Foundry, Inc. DATE OF NAME CHANGE: 20050127 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Momentive Specialty Chemicals Investments Inc. CENTRAL INDEX KEY: 0001315753 IRS NUMBER: 510370359 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: (614) 225-4000 MAIL ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 FORMER COMPANY: FORMER CONFORMED NAME: Borden Chemical Investments, Inc. DATE OF NAME CHANGE: 20050127 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Oilfield Technology Group, Inc CENTRAL INDEX KEY: 0001346731 IRS NUMBER: 202873694 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 15115 PARK ROW STREET 2: SUITE 110 CITY: HOUSTON STATE: TX ZIP: 77084 BUSINESS PHONE: 218-646-2800 MAIL ADDRESS: STREET 1: 15115 PARK ROW STREET 2: SUITE 110 CITY: HOUSTON STATE: TX ZIP: 77084 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MOMENTIVE INTERNATIONAL INC CENTRAL INDEX KEY: 0001346732 IRS NUMBER: 202833048 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: 614-225-4000 MAIL ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 FORMER COMPANY: FORMER CONFORMED NAME: Borden Chemical International, Inc DATE OF NAME CHANGE: 20051213 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Momentive CI Holding CO (China) LLC CENTRAL INDEX KEY: 0001347225 IRS NUMBER: 203907441 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: 614-225-4000 MAIL ADDRESS: STREET 1: 180 EAST BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 FORMER COMPANY: FORMER CONFORMED NAME: Hexion CI Holding CO (China) LLC DATE OF NAME CHANGE: 20051219 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NL Coop Holdings LLC CENTRAL INDEX KEY: 0001515736 IRS NUMBER: 272090696 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 180 E. BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: 614 225 4000 MAIL ADDRESS: STREET 1: 180 E. BROAD STREET CITY: COLUMBUS STATE: OH ZIP: 43215 CORRESP 1 filename1.htm ACCELERATION REQUEST

HEXION U.S. FINANCE CORP.

HEXION NOVA SCOTIA FINANCE, ULC

180 East Broad Street

Columbus, Ohio 43215

May 3, 2012

VIA EDGAR

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549-7010

Hexion U.S. Finance Corp.

Hexion Nova Scotia Finance, ULC

and the other Registrants (as defined below)

Registration Statement on Form S-1 (File No. 333-176961)

Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-1 (the “Registration Statement”) of Hexion U.S. Finance Corp. (“Hexion U.S.”), Hexion Nova Scotia Finance, ULC (“Hexion Nova Scotia”), Momentive Specialty Chemicals Inc. (the “Company”) and certain of the Company’s subsidiaries set forth below (together with Hexion U.S., Hexion Nova Scotia and the Company, the “Registrants”) be accelerated to May 7, 2012 at 11:00 a.m. Eastern Time or as soon thereafter as may be practicable.

Each of the Registrants hereby acknowledges that:

 

  •  

should the Securities and Exchange Commission (the “Commission”) or the Staff of the Commission (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;

 

  •  

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and

  •  

the Registrants 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.

We understand that the Staff will consider this request as confirmation by the Registrants of their awareness of their responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.

If you have any questions regarding the foregoing, please contact David S. Huntington (212-373-3124) or David E. Sobel (212-373-3226) of Paul, Weiss, Rifkind, Wharton & Garrison LLP.

 

Very truly yours,
Hexion U.S. Finance Corp.
Hexion Nova Scotia Finance, ULC
Momentive Specialty Chemicals Inc.
Momentive Specialty Chemicals Investments Inc.
Borden Chemical Foundry, LLC
HSC Capital Corporation
Lawter International Inc.
Momentive International Inc.
Oilfield Technology Group, Inc.
Momentive CI Holding Company (China) LLC
NL Coop Holdings LLC
By:  

/s/ Ellen G. Berndt

Name:   Ellen G. Berndt
Title:   Vice President and Secretary

 

Cc: David S. Huntington, Esq.

Paul, Weiss, Rifkind, Wharton & Garrison LLP