Graham Corporation

20 Florence Avenue

Batavia, New York

May 7, 2026

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 

Re:	Graham Corporation

Registration Statement on Form S-3

Filed April 30, 2026

(File No. 333-295458)

Ladies and Gentlemen:

In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, Graham Corporation, a Delaware corporation, hereby requests that the effectiveness of the registration statement on Form S-3 (File No. 333-295458), initially filed with the U.S. Securities and Exchange Commission on April 30, 2026, be accelerated so that the registration statement becomes effective at 4:00 p.m. Eastern Time on May 11, 2026 or as soon thereafter as practicable.

If you have any questions or comments, please contact Alexander McClean of Harter Secrest & Emery at (585) 231-1248.