[235 Chengnan Road, Wuxi High&New November 3, 2011 VIA EDGAR Cecilia Blye, Chief Office of Global Security Risk Division of Corporation Finance 100 F Street, N.E. Re: WSP Holdings Limited Form 20-F for the Fiscal Year Ended December 31, 2010 Initially filed on September 14, 2011 (File No. 1-33840 This letter sets forth our responses to the comments contained in]
[Contact: WSP Holdings Limited CCG Investor Relations, Inc. Ms. Judy Zhu, IR Director Ms. Elaine Ketchmere, Partner Phone: +86-510-8536-0401 Phone: +1-310-954-1345 (Los Angeles) E-mail: info@wsphl.com E-mail: elaine.ketchmere@ccgir.com http://www.wsphl.com http://www.ccgirasia.com Mr. Crocker Coulson, President Phone: +1-646-213-1915 (New York) Email: crocker.coulson@ccgir.com WSP Holdings Announces Second Quarter 2011 Results Wuxi, China, October 11, 2011 Second Quarter 2011 Highlights (Comparison with the first quarter] [FORM 6-K -------------- ---------- WSP HOLDINGS LIMITED No. 38 Zhujiang Road Xinqu, Wuxi, Jiangsu Province People's Republic of China X Form 20-F ____ WSP HOLDINGS LIMITED By : Name : Then Choon Hoi Title : Chief Financial Officer Description 99.1 Press Release 6-K 1 d28734.htm 6-K]
[Contact: WSP Holdings Limited CCG Investor Relations, Inc. Ms. Judy Zhu, IR Director Ms. Elaine Ketchmere, Partner Phone: +86-510-8536-0401 Phone: +1-310-954-1345 (Los Angeles) E-mail: info@wsphl.com E-mail: elaine.ketchmere@ccgir.com http://www.wsphl.com http://www.ccgirasia.com Mr. Crocker Coulson, President Phone: +1-646-213-1915 (New York) Email: crocker.coulson@ccgir.com WSP Holdings Announces Second Quarter 2011 Results Wuxi, China, October 11, 2011 Second Quarter 2011 Highlights (Comparison with the first quarter] [FORM 6-K -------------- ---------- WSP HOLDINGS LIMITED No. 38 Zhujiang Road Xinqu, Wuxi, Jiangsu Province People's Republic of China X Form 20-F ____ WSP HOLDINGS LIMITED By : Name : Then Choon Hoi Title : Chief Financial Officer Description 99.1 Press Release 6-K 1 d28734.htm 6-K]
[FORM 20-F/A (Amendment No.1) (Mark One) [ ] OR [X] For the fiscal year ended December 31, 2010. OR [ ] For the transition period from to OR [ ] Date of event requiring this shell company report WSP HOLDINGS LIMITED N/A Cayman Islands (Jurisdiction of Incorporation or Organization) No. 38 Zhujiang Road Xinqu, Wuxi Jiangsu Province People’s Republic of] [Certification by the Chief Executive Officer to Section 302 of the Sarbanes-Oxley Act of 2002 I, Longhua Piao, certify that: 1. I have reviewed this annual report on Form 20-F of WSP Holdings Limited (the “Company”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact] [Certification by the Chief Financial Officer I, Choon-Hoi Then, certify that: 1. I have reviewed this annual report on Form 20-F of WSP Holdings Limited (the “Company”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of]
[FORM 20-F/A (Amendment No.1) (Mark One) [ ] OR [X] For the fiscal year ended December 31, 2010. OR [ ] For the transition period from to OR [ ] Date of event requiring this shell company report WSP HOLDINGS LIMITED N/A Cayman Islands (Jurisdiction of Incorporation or Organization) No. 38 Zhujiang Road Xinqu, Wuxi Jiangsu Province People’s Republic of] [Certification by the Chief Executive Officer to Section 302 of the Sarbanes-Oxley Act of 2002 I, Longhua Piao, certify that: 1. I have reviewed this annual report on Form 20-F of WSP Holdings Limited (the “Company”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact] [Certification by the Chief Financial Officer I, Choon-Hoi Then, certify that: 1. I have reviewed this annual report on Form 20-F of WSP Holdings Limited (the “Company”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of]
[None (Title of Class) None (Title of Class) Indicate the number of outstanding shares of each of the Issuer’s classes of capital or common stock as of the close of the period covered by the annual report. 204,375,226 ordinary shares, par value $0.0001 per share, as of December 31, 2010. [ ] [X] Yes [ ] [X] Yes [X] [] [Wuxi Seamless Oil Pipe Co., Ltd. (As Borrower) Bank of China Limited Jiangsu Branch (As Arranging Bank) Bank of China Limited Wuxi Branch Agricultural Bank of China Limited Wuxi Branch (As Co-lead Bank) Bank of China Limited Wuxi Branch Agricultural Bank of China Limited Wuxi Branch Nanyang Commercial Bank (China) Limited Wuxi Branch China Merchants Bank Co., Ltd. Wuxi Branch] [Name of Subsidiaries Place of Incorporation 1. First Space Holdings Limited British Virgin Islands 2. Wuxi Seamless Oil Pipes Co. Ltd. PRC 3. Liaoyang Seamless Oil Pipes Co. Ltd. PRC 4. Houston OCTG Group, Inc. 5. Mengfeng Special Steel Co. Ltd. PRC 6. Bazhou Seamless Oil Pipes Co. Ltd. PRC 7. Songyuan Seamless Oil Pipes Co. Ltd. PRC 8. Chaoyang] [Certification by the Chief Executive Officer I, Longhua Piao, certify that: 1. 2. 3. 4. (a) (b) (c) (d) 5. (a) (b) EX-12.1 8 d28278_ex12-1.htm EX-12.1] [Certification by the Chief Financial Officer I, Choon-Hoi Then, certify that: 1. 2. 3. 4. (a) (b) (c) (d) 5. (a) (b) EX-12.2 9 d28278_ex12-2.htm EX-12.2] [Certification by the Chief Executive Officer (1) (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. EX-13.1 10 d28278_ex13-1.htm EX-13.1] [Certification by the Chief Financial Officer (1) (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. Choon-Hoi Then EX-13.2 11 d28278_ex13-2.htm EX-13.2] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the incorporation by reference in the Registration Statement No. 333-153582 on Form S-8 of our reports dated September 14, 2011, relating to the consolidated financial statements and financial statement schedule of WSP Holdings Limited and its subsidiaries (collectively, the “Company”) (which report expresses an unqualified opinion and includes an explanatory]
[None (Title of Class) None (Title of Class) Indicate the number of outstanding shares of each of the Issuer’s classes of capital or common stock as of the close of the period covered by the annual report. 204,375,226 ordinary shares, par value $0.0001 per share, as of December 31, 2010. [ ] [X] Yes [ ] [X] Yes [X] [] [Wuxi Seamless Oil Pipe Co., Ltd. (As Borrower) Bank of China Limited Jiangsu Branch (As Arranging Bank) Bank of China Limited Wuxi Branch Agricultural Bank of China Limited Wuxi Branch (As Co-lead Bank) Bank of China Limited Wuxi Branch Agricultural Bank of China Limited Wuxi Branch Nanyang Commercial Bank (China) Limited Wuxi Branch China Merchants Bank Co., Ltd. Wuxi Branch] [Name of Subsidiaries Place of Incorporation 1. First Space Holdings Limited British Virgin Islands 2. Wuxi Seamless Oil Pipes Co. Ltd. PRC 3. Liaoyang Seamless Oil Pipes Co. Ltd. PRC 4. Houston OCTG Group, Inc. 5. Mengfeng Special Steel Co. Ltd. PRC 6. Bazhou Seamless Oil Pipes Co. Ltd. PRC 7. Songyuan Seamless Oil Pipes Co. Ltd. PRC 8. Chaoyang] [Certification by the Chief Executive Officer I, Longhua Piao, certify that: 1. 2. 3. 4. (a) (b) (c) (d) 5. (a) (b) EX-12.1 8 d28278_ex12-1.htm EX-12.1] [Certification by the Chief Financial Officer I, Choon-Hoi Then, certify that: 1. 2. 3. 4. (a) (b) (c) (d) 5. (a) (b) EX-12.2 9 d28278_ex12-2.htm EX-12.2] [Certification by the Chief Executive Officer (1) (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. EX-13.1 10 d28278_ex13-1.htm EX-13.1] [Certification by the Chief Financial Officer (1) (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. Choon-Hoi Then EX-13.2 11 d28278_ex13-2.htm EX-13.2] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the incorporation by reference in the Registration Statement No. 333-153582 on Form S-8 of our reports dated September 14, 2011, relating to the consolidated financial statements and financial statement schedule of WSP Holdings Limited and its subsidiaries (collectively, the “Company”) (which report expresses an unqualified opinion and includes an explanatory]
[WSP Holdings Restructures Short-term Debt with Syndicated Loan from Eight Commercial Banks WUXI, China, Sep. 08, 2011 The syndicated loan facility allows the Company to replace its existing short-term borrowings with mid-term working capital loans and helps the Company improve its current cash flow position and liquidity. The credit facility consists of approximately 60% working capital loans and 40% trade] [FORM 6-K -------------- ---------- WSP HOLDINGS LIMITED No. 38 Zhujiang Road Xinqu, Wuxi, Jiangsu Province People's Republic of China X Form 20-F ____ (1):________________ (7):________________ WSP HOLDINGS LIMITED Name : Then Choon Hoi Title : Chief Financial Officer 99.1 Press release 6-K 1 d28631.htm 6-K]
