KRONOS WORLDWIDE, INC.
                              Three Lincoln Centre
                          5430 LBJ Freeway, Suite 1700
                                Dallas, TX 75240


                                November 29, 2004

VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:   Kronos Worldwide, Inc. -- Withdrawal of Registration Statement on Form S-1
      File No. 333-119639

Ladies and Gentlemen:

Pursuant to Rule 477  promulgated  under the  Securities Act of 1933, as amended
(the "Securities Act"), Kronos Worldwide,  Inc. (the "Company"),  hereby applies
for  the  withdrawal  of its  Registration  Statement  on  Form  S-1  (File  No.
333-119639),   together   with  all   exhibits  and   amendments   thereto  (the
"Registration Statement").  The Registration Statement was originally filed with
the Securities and Exchange Commission (the "Commission") on October 8, 2004.

The  Registration  Statement  relates  to a public  offering  of  shares  of the
Company's common stock. The Company is requesting withdrawal of the Registration
Statement  because it believes that current market  conditions  make  proceeding
with this offering inadvisable at this time. The Registration  Statement has not
been declared effective by the Commission,  and none of the Company's securities
have been sold in  connection  with this  offering.  The Company may undertake a
subsequent  private  offering  of  securities  in reliance on Rule 155(c) of the
Securities Act.

The Company  requests,  in accordance with Rule 457(p) under the Securities Act,
that all fees  paid to the  Commission  in  connection  with the  filing  of the
Registration  Statement be credited to the account of the Company for future use
by the Company, a majority-owned subsidiary of the Company or a parent that owns
more than 50% of the Company's outstanding voting securities. Please provide the
Company  with a copy  of  the  order  granting  withdrawal  of the  Registration
Statement as soon as it is available.

If you have any questions  regarding the foregoing  application  for withdrawal,
please  contact me at (972)  450-4289 or Don M.  Glendenning  of Locke Liddell &
Sapp LLP at (214) 740-8623.

Very truly yours,

KRONOS WORLDWIDE, INC.



By:   /s/ Robert D. Graham
      -----------------------------------
      Robert D. Graham
      Vice President and General Counsel