GERMER
GERTZ, L.L.P.
ATTORNEYS AT
LAW
AUSTIN
BEAUMONT
HOUSTON
www.germer.com
Charles
W. Goehringer, Jr.
Partner
Direct
Line: 409.654.6765
cwgoehringer@germer.com
June 16,
2008
Mr. Chris
White
Branch
Chief
Division
of Corporate Finance
United
States Securities and Exchange Commission
Mail Stop
7010
Washington,
D.C. 20549-7010
Re: Arabian
American Development Company
Form 10-K for Fiscal Year Ended
December 31, 2007
Filed
March 14, 2008
Form 10-Q
for Fiscal Quarter Ended March 31, 2008
Filed May
12, 2008
File No. 1-33926
Dear Mr.
White:
We are general counsel for Arabian
American Development Company (the “Company”). We recently received
your letter dated June 12, 2008, to Mr. Hatem El Khalidi requesting various
revisions to financial statements and related disclosures to the above
filings.
On page 3 under Closing Comments, the
Company is instructed to amend its filings and respond to the comments contained
in your letter within 10 business days or advise when the Company will provide a
response. The Company respectfully requests that it be permitted to
respond to the comments and amend its filings as required on or before July 11,
2008. Please be advised that the Company fully intends to cooperate
in all respects with your office, but requires this extension due to vacations
of key personnel.
Sincerely,
GERMER GERTZ, L.L.P.
By: /s/ Charles W. Goehringer,
Jr.
Charles
W. Goehringer, Jr.
CWG/rr
550
FANNIN, SUITE 400 • BEAUMONT, TX
77701
P. O. BOX 4915
• BEAUMONT,
TX 77704 • PHONE: 409.654.6700 • FAX: 409.835.2115
CWG/632269