VALHI, INC.
5430 LBJ Freeway, Suite 1700
Dallas, Texas 75240
FOIA CONFIDENTIAL TREATMENT REQUEST BY VALHI, INC.
September 15, 2015
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mr. Terence O'Brien, Accounting Branch Chief
Division of Corporation Finance
CC: Ms. Tracie Mariner
Division of Corporation Finance
Ms. Jeanne Baker
Division of Corporation Finance
RE: Valhi, Inc.
Form 10-Q for Fiscal Quarter Ended June 30, 2015 Filed August 7, 2015
File No. 333-48391
Dear Mr. O'Brien
Exhibit A to this letter, pages 1 through 5 thereof (collectively, the "Information"), is hereby submitted to you in response to the Staff's letter dated August 31, 2015 (the "Comment Letter") concerning the above referenced Forms 10-Q of Valhi, Inc. ("Valhi"). The Information is being supplementally provided to you in response to comment number 1 in the Comment Letter.
Pursuant to 17 C.F.R. § 200.83(c), the undersigned hereby requests on behalf of Valhi that the Commission afford the Information confidential treatment for reasons of business confidentiality, and that no portion thereof be disclosed if a request for disclosure is made under the Freedom of Information Act, 5 U.S.C. § 522. Pursuant to the Commission Rule of Information Request, 17 C.F.R. § 200.83, each page of the Information is clearly marked "Confidential Treatment Requested."
If you have any questions, you may contact the undersigned at 972-450-4228.
Securities and Exchange Commission
September 15, 2015
Page 2
Sincerely,
/s/ Gregory M. Swalwell
Gregory M. Swalwell,
Executive Vice President and Controller
CC: Office of Freedom of Information and Privacy Act Operations (w/o enclosure)
Securities and Exchange Commission
U.S. Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 2736
Washington, D.C. 20549
Exhibit A – Page 1 of 5
Document Supplementally Provided to the Securities and Exchange Commission September 15, 2015
Confidential Treatment Requested by Valhi, Inc.
Pre-tax Income (Loss) Generated by German and Belgian Jurisdictions
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Germany
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Corporate
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Trade
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Tax
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Tax
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Belgium
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(In euro millions)
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Year ended December 31, 2012
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Year ended December 31, 2013
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Year ended December 31, 2014
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Quarter ended March 31, 2015
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Six months ended June 30, 2015
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[*] Information omitted pursuant to a request for confidential treatment filed with the SEC by Valhi, Inc.
Exhibit A – Page 2 of 5
Document Supplementally Provided to the Securities and Exchange Commission September 15, 2015
Confidential Treatment Requested by Valhi, Inc.
German and Belgian NOL Carryforwards
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Germany
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Corporate
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Trade
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Tax
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Tax
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Belgium
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(In euro millions)
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March 31, 2015
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June 30, 2015
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[*] Information omitted pursuant to a request for confidential treatment filed with the SEC by Valhi, Inc.
Exhibit A – Page 3 of 5
Document Supplementally Provided to the Securities and Exchange Commission September 15, 2015
Confidential Treatment Requested by Valhi, Inc.
Expected Level of Pre-Tax Profits For Calendar 2015 For German and Belgian Operations
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Germany
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Belgium
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(In $ millions)
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Actual pre-tax profits - year ended
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December 31, 2014
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Expected level of pre-tax profit
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(loss) for calendar 2015 at:
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December 31, 2014
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March 31, 2015
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June 30, 2015
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[*] Information omitted pursuant to a request for confidential treatment filed with the SEC by Valhi, Inc.
Exhibit A – Page 4 of 5
Document Supplementally Provided to the Securities and Exchange Commission September 15, 2015
Confidential Treatment Requested by Valhi, Inc.
Sales For German and Belgian Operations
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Sales
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Germany
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Belgium
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(In $ millions)
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Year ended December 31, 2013
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Year ended December 31, 2014
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Quarter ended March 31, 2014
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Quarter ended March 31, 2015
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Quarter ended June 30, 2014
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Quarter ended June 30, 2015
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Six months ended June 30, 2014
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Six months ended June 30, 2015
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[*] Information omitted pursuant to a request for confidential treatment filed with the SEC by Valhi, Inc.
Exhibit A – Page 5 of 5
Document Supplementally Provided to the Securities and Exchange Commission September 15, 2015
Confidential Treatment Requested by Valhi, Inc.
Gross Margin For German and Belgian Operations
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Gross Margin
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Germany
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Belgium
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(In $ millions)
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Year ended December 31, 2013
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Year ended December 31, 2014
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Quarter ended March 31, 2014
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Quarter ended March 31, 2015
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Quarter ended June 30, 2014
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Quarter ended June 30, 2015
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Six months ended June 30, 2014
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Six months ended June 30, 2015
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[*] Information omitted pursuant to a request for confidential treatment filed with the SEC by Valhi, Inc.