Koppers Inc.
436 Seventh Avenue
Pittsburgh, PA 15219
May 12, 2010
Mr. Jay Ingram
Legal Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing and Construction
100 F Street, NE
Washington, D.C. 20549-4631
| Re: | Koppers Inc. |
Registration Statement on Form S-4
File No. 333-165108
Dear Mr. Ingram:
In accordance with Rule 461 under the Securities Act of 1933, as amended, Koppers Inc. and the co-registrants listed on Annex A hereto (collectively, the “Registrants”), hereby respectfully request that the effective date of the above referenced Registration Statement on Form S-4 be accelerated to 5:30 p.m. (Eastern Time) Wednesday, May 12, 2010, or as soon thereafter as practicable.
The Registrants acknowledge that:
| • | should the Securities and Exchange Commission (the “Commission”)or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve us from our full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and |
| • | we 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 or comments regarding the foregoing, please do not hesitate to contact me at (412-227-2889).
| Sincerely, |
| /s/ Steven R. Lacy, Esq. |
| Steven R. Lacy, Esq. |
| Senior Vice President, Administration, General Counsel and Secretary |
| Koppers Inc. |
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ANNEX A
| Co-Registrant |
File No. | |
| Koppers Ventures LLC |
333-165108-01 | |
| Koppers Asia LLC |
333-165108-02 | |
| Koppers Delaware, Inc |
333-165108-03 | |
| Concrete Partners, Inc. |
333-165108-04 | |
| Koppers Concrete Products, Inc. |
333-165108-05 | |
| World-Wide Ventures Corporation |
333-165108-06 | |
| Koppers Holdings Inc. |
333-165108-07 |
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