MERCER
INTERNATIONAL INC.
Suite
2840, 650 West Georgia Street
Vancouver,
British Columbia, Canada V6B 4N8
December
12, 2005
Securities
and Exchange Commission
100
F
Street, N.E.
Washington,
D.C. 20549
Re: Mercer
International Inc. - Request for Withdrawal of Form S-3/A
Ladies
and Gentlemen:
Mercer
International Inc. hereby submits this letter to notify the Securities and
Exchange Commission of an inadvertent EDGAR filing. On December 8, 2005, Mercer
International Inc. filed with the SEC via EDGAR Post-Effective Amendment No.
1
to Form S-3 (file number 333-111118) on form type S-3/A (accession number
0001012410-05-000115), rather than as a post-effective amendment on form type
POS AM, as indicated on the face of the filing. Pursuant to Rule 477 under
the
Securities
Act of 1933,
as
amended, Mercer International Inc. hereby requests the withdrawal of the Form
S-3/A. Mercer International Inc. intends to refile Post-Effective Amendment
No.
1 to Form S-3 under form type POS AM later today to correct the error. No
securities were sold under Post-Effective Amendment No. 1 to Form
S-3.
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Sincerely,
MERCER
INTERNATIONAL INC.
By:
/s/ David M. Gandossi
Name:
David
M. Gandossi
Title:
Executive
Vice-President,
Chief
Financial Officer and Secretary
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