HUNTON & WILLIAMS LLP                 

RIVERFRONT PLAZA, EAST TOWER

951 EAST BYRD STREET                       

RICHMOND, VIRGINIA 23219-4074     

TEL         804 ? 788 ? 8200

FAX        804 ? 788 ? 8218

May     , 2003

Board of Directors

Ethyl Corporation

330 South Fourth Street

Richmond, Virginia 23219

Ethyl Corporation

Registration Statement on Form S-4 for Exchange

of Outstanding 8 ⁷/8% Notes due 2010

for 8 ⁷/8% Senior Notes due 2010

to be Registered under the Securities Act of 1933

Ladies and Gentlemen:

We have acted as counsel to Ethyl Corporation, a Virginia corporation (the ?Company?), in connection with the registration under the Securities Act of 1933, as amended (the ?Securities Act?), of $150,000,000 aggregate principal amount of 8 ⁷/8% Senior Notes due 2010 (the ?Exchange Notes?). The Exchange Notes are to be issued in exchange (the ?Exchange Offer?) for an equal aggregate principal amount of unregistered 8 ⁷/8% Senior Notes due 2010 (the ?Old Notes?), issued on April 30, 2003 in reliance on an exemption from registration under the Securities Act for offers and sales of securities not involving public offerings. The Exchange Notes will be issued pursuant to the terms of an Indenture, dated as of April 30, 2003, among the Company and Wells Fargo Bank Minnesota, National Association, as trustee. The terms of the Exchange Offer are described in the Registration Statement on Form S-4 (the ?Registration Statement?) filed by the Company with the Securities and Exchange Commission (the ?Commission?) for the registration of the Exchange Notes under the Securities Act.

Home        Intelligence        Services        Subscriptions        News        About Us

Contact Us       Terms of Use       Resend Documents       Shopping Cart

Copyright © 2008 The Consus Group LLC