0001193125-13-380577.txt : 20131129 0001193125-13-380577.hdr.sgml : 20131128 20130926211854 ACCESSION NUMBER: 0001193125-13-380577 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20130926 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ASSOCIATED MATERIALS, LLC CENTRAL INDEX KEY: 0000802967 STANDARD INDUSTRIAL CLASSIFICATION: PLASTICS PRODUCTS, NEC [3089] IRS NUMBER: 751872487 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 3773 STATE ROAD CITY: CUYAHOGA FALLS STATE: OH ZIP: 44223 BUSINESS PHONE: 330 929 1811 MAIL ADDRESS: STREET 1: 3773 STATE ROAD CITY: CUYAHOGA FALLS STATE: OH ZIP: 44223 FORMER COMPANY: FORMER CONFORMED NAME: ASSOCIATED MATERIALS LLC DATE OF NAME CHANGE: 20080227 FORMER COMPANY: FORMER CONFORMED NAME: ASSOCIATED MATERIALS INC DATE OF NAME CHANGE: 19930623 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Gentek Building Products, Inc. CENTRAL INDEX KEY: 0001477568 IRS NUMBER: 311533669 STATE OF INCORPORATION: DE FISCAL YEAR END: 0102 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 3773 STATE ROAD CITY: CUYAHOGA FALLS STATE: OH ZIP: 44223 BUSINESS PHONE: 330-929-1811 MAIL ADDRESS: STREET 1: 3773 STATE ROAD CITY: CUYAHOGA FALLS STATE: OH ZIP: 44223 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Gentek Holdings, LLC CENTRAL INDEX KEY: 0001477569 IRS NUMBER: 311533672 STATE OF INCORPORATION: DE FISCAL YEAR END: 0102 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 3773 STATE ROAD CITY: CUYAHOGA FALLS STATE: OH ZIP: 44223 BUSINESS PHONE: 330-929-1811 MAIL ADDRESS: STREET 1: 3773 STATE ROAD CITY: CUYAHOGA FALLS STATE: OH ZIP: 44223 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AMH New Finance, Inc. CENTRAL INDEX KEY: 0001516502 IRS NUMBER: 273533185 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 3773 STATE ROAD CITY: CUYAHOGA FALLS STATE: OH ZIP: 44223 BUSINESS PHONE: 330-929-1811 MAIL ADDRESS: STREET 1: 3773 STATE ROAD CITY: CUYAHOGA FALLS STATE: OH ZIP: 44223 CORRESP 1 filename1.htm CORRESP

Associated Materials, LLC

AMH New Finance, Inc.

3773 State Road

Cuyahoga Falls, OH 44223

September 26, 2013

VIA EDGAR

Ms. Pamela Long

Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E., Mailstop 4631

Washington, D.C. 20549

 

  Re: Associated Materials, LLC and AMH New Finance, Inc.
     Registration Statement on Form S-4
     File No.: 333-190108

Ladies and Gentlemen:

Associated Materials, LLC (the “Company”) and AMH New Finance, Inc. (“New Finance” and, together with the Company, the “Registrants”), pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), hereby request that the effective date of the above-referenced Registration Statement on Form S-4 of the Registrants be accelerated so that the Registration Statement may become effective at 12:00 p.m. New York time on September 30, 2013, or as soon as possible thereafter. In this regard, the Registrants are aware of their obligations under the Act.

Pursuant to this request, the Registrants acknowledge that:

 

  •   should the Securities and Exchange Commission (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;

 

  •   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 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 this request for acceleration of effectiveness, please contact William B. Brentani or Daniel N. Webb, each of Simpson Thacher & Bartlett LLP, at (650) 251-5110 or (650) 251-5095, respectively.

[Signature Page Follows]

Very truly yours,
ASSOCIATED MATERIALS, LLC
By:  

/s/ Paul Morrisroe

Name:   Paul Morrisroe
Title:   Senior Vice President and Chief Financial Officer
AMH NEW FINANCE, INC.
By:  

/s/ Paul Morrisroe

Name:   Paul Morrisroe
Title:   Senior Vice President and Chief Financial Officer

[Signature Page to Acceleration Request Letter]