(CALFEE, HALTER & GRISWOLD LLP LOGO)

                          CALFEE, HALTER & GRISWOLD LLP
                                ATTORNEYS AT LAW
                                    Cleveland

                          Direct Dial No. 216/622-8667
                             email: ahall@calfee.com


                                November 16, 2004


VIA EDGAR

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

                           Re:      RPM International Inc.
                                    Registration Statement on Form S-4

Ladies and Gentlemen:

                  On behalf of RPM International Inc., a Delaware corporation
(the "Company"), in connection with the Company's offer to exchange all of the
outstanding RPM International Inc. 4.45% Senior Notes due 2009 for new 4.45%
Senior Notes due 2009 registered under the Securities Act of 1933 (such event
referred to as the "Exchange Offer"), we are hereby transmitting for filing
pursuant to the Securities Act of 1933 and the Electronic Data Gathering,
Analysis, and Retrieval system, a registration statement on Form S-4, with
Exhibits, with respect to the Exchange Offer.

                  The Company has transmitted the filing fee of $25,340.00 by
wire transfer to the Securities and Exchange Commission's lockbox account at
Mellon Bank.

                  Please direct any comments or inquiries regarding this filing
to the undersigned at (216) 622-8667.

                                        Very truly yours,

                                        /s/ Arthur C. Hall III
                                        Arthur C. Hall III


cc:      P. Kelly Tompkins, Esq.
         Edward W. Moore, Esq.




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