SEC Division of Corporation Finance no-action letter: International Wire Group, Inc.

Weil, Gotshal AUSTIN & Manges llp
BEIJING
200 CRESCENT COURT
BOSTON SUITE 300
BUDAPEST DALLAS, TEXAS 75201-6950
DUBAI (214) 746-7700
FAX: (214) 746-7777 FRANKFURT
HONG KONG
HOUSTON
LONDON
MIAMI
DIRECT LINE
MUNICH (214) 746-7738 tt h @ il November 4, 2009 NEW YORK PARIS PRAGUE PROVIDENCE SHANGHAI SILICON VALLEY Securities Exchange Act of 1934, Section 12(h); Rule 12h-3 Securities Exchange Act of 1934, Section 13(a) Securities Exchange Act of 1934, Section 15(d) VIA EMAIL (cfletters@sec.gov) Division of Corporation Finance Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: International Wire Group, Inc. – Commission File No. 000-51043 Dear Office of Chief Counsel:
On behalf of our client, International Wire Group, Inc., a Delaware corporation (the “Company”), we hereby request that the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) confirm that it concurs in the Company’s view that the effectiveness of its registration statement on Form S-8 during the year ending December 31, 2009 in connection with the incorporation by reference therein of the Company’s Form 10-K for the year ended December 31, 2008, as filed with the Commission on March 12, 2009, would not preclude the Company from utilizing Rule 12h-3 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), to suspend its duty to file with the Commission current and periodic reports required by Sections 13(a) and 15(d) of the Exchange Act and the rules and regulations promulgated thereunder for the fiscal year in which the Company’s registration statement on Form S-8 became effective or were