CORRESP: A correspondence can be sent as a document with another submission type or can be sent as a separate submission.
Published on June 28, 2010
June 28, 2010
VIA FACSIMILE AND EDGAR
United States Securities and Exchange Commission
Washington, D.C. 20549
Attention: Erin Wilson
Mail Stop 3561
Washington, D.C. 20549
Attention: Erin Wilson
Mail Stop 3561
Re: | Graphic Packaging Holding Company | |||
Graphic Packaging International, Inc. | ||||
Graphic Packaging Corporation | ||||
Bluegrass Container Canada Holdings, LLC | ||||
Bluegrass Flexible Packaging Company, LLC | ||||
Bluegrass Labels Company, LLC | ||||
Bluegrass Multiwall Bag Company, LLC | ||||
Field Container Queretaro (USA), L.L.C. | ||||
Graphic Packaging Flexible Holdings, LLC | ||||
Handschy Holdings, LLC | ||||
Handschy Industries, LLC | ||||
Riverdale Industries, LLC | ||||
Amendment No. 1 to Registration Statement on Form S-3 | ||||
Filed on May 25, 2010 | ||||
File No. 333-166324 |
Dear Ms. Wilson:
On May 25, 2010, Graphic Packaging Holding Company (the Company), Graphic Packaging
International, Inc. and the additional registrants listed on Exhibit A (collectively with the
Company, the Registrants) filed via EDGAR Amendment No. 1 to the above-referenced Registration
Statement on Form S-3 (Amendment No. 1 to the Registration Statement).
The Registrants acknowledge that (i) should the Securities and Exchange Commission (the
Commission) or the staff of the Commission, acting pursuant to delegated authority, declare the
filing effective, such declaration does not foreclose the Commission from taking any action with
respect to the filing; (ii) the action of the Commission or the staff of the Commission, 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 (iii) 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.
Sincerely, GRAPHIC PACKAGING HOLDING COMPANY GRAPHIC PACKAGING INTERNATIONAL, INC. GRAPHIC PACKAGING CORPORATION BLUEGRASS CONTAINER CANADA HOLDINGS, LLC BLUEGRASS FLEXIBLE PACKAGING COMPANY, LLC BLUEGRASS LABELS COMPANY, LLC BLUEGRASS MULTIWALL BAG COMPANY, LLC FIELD CONTAINER QUERETARO (USA), L.L.C. GRAPHIC PACKAGING FLEXIBLE HOLDINGS, LLC HANDSCHY HOLDINGS, LLC HANDSCHY INDUSTRIES, LLC RIVERDALE INDUSTRIES, LLC |
||||
By: | /s/ Laura Lynn Smith | |||
Laura Lynn Smith | ||||
Assistant Secretary | ||||
cc: Justin R. Howard
EXHIBIT A
Graphic Packaging Corporation
Bluegrass Container Canada Holdings, LLC
Bluegrass Flexible Packaging Company, LLC
Bluegrass Labels Company, LLC
Bluegrass Multiwall Bag Company, LLC
Field Container Queretaro (USA), L.L.C.
Graphic Packaging Flexible Holdings, LLC
Handschy Holdings, LLC
Handschy Industries, LLC
Riverdale Industries, LLC
Bluegrass Container Canada Holdings, LLC
Bluegrass Flexible Packaging Company, LLC
Bluegrass Labels Company, LLC
Bluegrass Multiwall Bag Company, LLC
Field Container Queretaro (USA), L.L.C.
Graphic Packaging Flexible Holdings, LLC
Handschy Holdings, LLC
Handschy Industries, LLC
Riverdale Industries, LLC