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Published on January 3, 2005
January 3, 2005
By Facsimile and EDGAR
Ms. Pamela Ann Long,
Securities and Exchange Commission,
450 Fifth Street, N.W.,
Washington, D.C. 20549.
Dear Ms. Long:
In accordance with Rule 12d1-2 under the Securities Exchange
Act of 1934, as amended, Novelis Inc. (the "Company") hereby respectfully
requests acceleration of effectiveness of its Registration Statement on Form 10,
File No. 001-32312 (the "Registration Statement") to 9:30 a.m., Eastern Standard
Time, on January 4, 2005, or as soon thereafter as practicable. The Company
requests acceleration of effectiveness of the Registration Statement so that it
may complete its separation from Alcan Inc. as described in the Registration
Statement as soon as practicable.
The Company acknowledges that (1) should the U.S. Securities
and Exchange Commission (the "Commission") or the Staff, acting pursuant to
delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing; (2) the action of
the Commission or the Staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing;
and (3) the Company may not assert this action as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.
Ms. Pamela Ann Long -2-
Sincerely,
Novelis Inc.
By: /s/ Brian W. Sturgell
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Brian W. Sturgell
Chief Executive Officer