1.

We also note your statement that you have a significant competitive advantage because your mines supply your feedstock requirements for all of your European sulfate-process plants and you also sell ilmenite ore to third parties, some of whom are your competitors.  In order to assess the significance of your mining operations for purposes of Industry Guide 7, supplementally, please provide the asset valuations for these two mines to the point of external sales, along with the net profits, and total revenues for these mining/processing facilities to verify their materiality.  We may have further comments pending your response.

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The net book value of the assets (buildings and equipment) used in the Company's mining operations was only 3.0% and 3.4% of the Company's consolidated total assets at December 31, 2014 and 2015, respectively;

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Third-party sales attributable to such mining operations were only 5.6%, 5.5% and 3.6% of the Company's consolidated net sales for the years ended December 31, 2013, 2014 and 2015, respectively;

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Third-party sales attributable to such mining operations have historically represented approximately two-thirds of the ilmenite ore we produce from our mines, with the remaining one-third consumed internally as a source of feedstock ore for our European sulfate-process production facilities (although depending on the needs of our third-party customers, in some years our internal consumption may represent a greater percentage than one-third).  However, such internally-consumed feedstock ore does not represent a significant portion of the Company's total cost of sales.  The cost of our mining operations related to feedstock ore internally consumed was only 2.4%, 3.1% and 2.8% of the Company's consolidated cost of sales for the years ended December 31, 2013, 2014 and 2015, respectively; and

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The availability of such internal source of feedstock ore is not considered critical to our operations because we believe that generally we could satisfy such feedstock requirements from third party sources, if necessary. In this regard we note that the feedstock ore requirements for our Canadian sulfate-process production facility, which is similar in design to our European sulfate-process production facilities, is sourced from a third party.

2.

We note your statement that you own and operate two ilmenite mines in Norway with reserves that are expected to last at least 50 years.  Please provide the reserve disclosure required by Instruction 3 of Item 102 of Regulation S-K, or explain to us why disclosure is not required.  Further, if disclosure is required, please forward to our engineer as supplemental information and not as part of your filing, your information that establishes the legal, technical, and economic feasibility of your materials designated as reserves.  The information requested includes, but is not limited to:

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Property and geologic maps

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Description of your sampling and assaying procedures

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Drill-hole maps showing drill intercepts

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Representative geologic cross-sections and drill logs

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Description and examples of your cut-off calculation procedures

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Cutoff grades used for each category of your reserves and resources

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Justifications for the drill hole spacing used to classify and segregate proven and probable reserves

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A detailed description of your procedures for estimating reserves

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Copies of any pertinent engineering or geological reports, and executive summaries of feasibility studies or mine plans which including the cash flow analyses

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A detailed permitting and government approval schedule for the project, particularly identifying the primary environmental or construction approval(s) and your current location on that schedule.

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KWI is responsible for the adequacy and accuracy of the disclosures in its filings with the Commission;

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Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to our filings with the Commission; and

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KWI may not assert Staff comments as a defense in any proceeding initiated by the Commission or any other person under the federal securities laws of the United States.