twin20180911_corresp.htm

Twin Disc, Incorporated

1328 Racine Street

Racine, Wisconsin

 

September 13, 2018

 

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington D.C. 20549

 

Attention: Geoff Kruczek

 

 

Re:

Twin Disc, Incorporated

 

 

Registration Statement on Form S-3

 

 

File No. 333-227130

 

Via EDGAR – Acceleration Request

 

 

Requested Date:

September 14, 2018

 

Requested Time:

9:30 Eastern Time

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Twin Disc, Incorporated (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-captioned Registration Statement on Form S-3 to become effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as is practicable. The Registrant hereby authorizes Kenneth A. Hoogstra, Esq., an attorney with the Registrant’s outside legal counsel, von Briesen & Roper, s.c., to orally modify or withdraw this request for acceleration.

 

The Registrant requests that it be notified of such effectiveness by a telephone call of Kenneth A. Hoogstra at (414) 287-1376, or in his absence, Katelyn A. Pellitteri at (414) 287-1493.

 

 

Sincerely,

 

 

 

Twin Disc Incorporated

 

 

 

By:

/s/ Jeffrey S. Knutson

 

 

Jeffrey S. Knutson

 

 

Vice President – Finance, Chief

Financial Officer, Treasurer and

Secretary

 

 

 

cc:

Kenneth A. Hoogstra, Esq.

 

von Briesen & Roper, s.c.