Arabian
American Development Company
P.O. Box
1636
Silsbee,
Texas 77656
(409)
385-8300
December
2, 2009
United
States Securities and Exchange Commission
Division
of Corporate Finance
100 F
Street, N.E.
Washington,
D.C. 20549
Attention:
Ms. Laura Nicholson
Re: Arabian
American development Company
Form 10-K for the Fiscal year Ended
December 31, 2008
Filed March 16, 2009
Form 10-Q
for the Fiscal Quarter Ended March 31, 2009
Filed May 8, 2009
Form 10-Q for the Fiscal Quarter Ended
June 30, 2009
Filed August 7, 2009
Form 10-Q for the Fiscal Quarter Ended
September 30, 2009
Filed November 6, 2009
File No. 1-33926
Dear Ms.
Nicholson:
Please allow this letter to confirm
that Arabian American Development Company will undertake to completely respond
to the comments contained in the United States Securities and Exchange
Commission’s November 30, 2009 correspondence, on or before January 8,
2009.
Thank you for your
consideration.
Sincerely,
/s/ Connie
Cook
Connie Cook
Treasurer