Acceleration Letter

0001193125-12-214837.txt : 20120731 0001193125-12-214837.hdr.sgml : 20120731 20120507153030 ACCESSION NUMBER: 0001193125-12-214837 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120507 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: 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 Letter

Hexion U.S. Finance Corp.

180 East Broad Street

Columbus, Ohio 43215

May 7, 2012

VIA EDGAR

Securities and Exchange Commission

Judiciary Plaza

100 F Street, N.E.

Washington, D.C. 20549

Hexion U.S. Finance Corp.

Momentive Specialty Chemicals Inc.

Lawter International Inc.

HSC Capital Corporation

Borden Chemical Foundry, LLC

Momentive Specialty Chemicals Investments Inc.

Oilfield Technology Group, Inc.

Momentive International Inc.

Momentive CI Holding Company (China) LLC

NL Coop Holdings LLC

Registration Statement on Form S-4 (File Nos. 333-180774, 333-180774-01, 333-180774-02,

333-180774-03, 333-180774-04, 333-180774-05, 333-180774-06, 333-180774-07, 333-180774- 08,

333-180774-09)

Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Hexion U.S. Finance Corp., a Delaware corporation (the “Company”), Momentive Specialty Chemicals Inc. (“MSC”) and certain of MSC’s subsidiaries (together with the Company and MSC, the “Registrants”), hereby request that the effective date of the above-captioned Registration Statement on Form S-4 (the “Registration Statements”) be accelerated to May 8, 2012 at 3:00 p.m. Eastern time or as soon thereafter as may be practicable.

We understand that the staff of the Securities and Exchange Commission (the “Commission”) will consider this request as confirmation by each of the Registrants of its awareness of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statements. In connection with the foregoing, each of the Registrants represents and acknowledges that:

Securities and Exchange Commission

•

should the Commission or the staff of the Commission, 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

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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.

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.

Sincerely,