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United States securities and exchange commission logo





                             December 21, 2022

       Scott Tozier
       Executive Vice President and Chief Financial Officer
       Albemarle Corporation
       4250 Congress St., Suite 900
       Charlotte, NC 28209

                                                        Re: Albemarle
Corporation
                                                            Form 10-K for the
year ended December 31, 2021
                                                            Filed February 22,
2022
                                                            File No. 001-12658

       Dear Scott Tozier:

              We have reviewed your December 1, 2022 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

               Please respond to these comments by providing the requested
information or advise us as
       soon as possible when you will respond. If you do not believe our
comments apply to your facts
       and circumstances, please tell us why in your response.

              After reviewing your response to these comments, we may have
additional comments.
       Unless we note otherwise, our references to prior comments are to
comments in our November 3,
       2022 letter.

       Form 10-K

       Controls and Procedures, page 127

   1.                                                   We have read your
response to comment 3 noting that you have re-assessed your
                                                        conclusion on the
effectiveness of your disclosure controls and procedures and that you
                                                        believe that they were
effective as of December 31, 2021. Based on the number and
                                                        nature of the
deficiencies noted, we continue to consider the omitted disclosures and
                                                        information required to
comply with SK 1300 to be material and do not agree with the
                                                        conclusion of your
re-assessment. Please revise to state that your disclosure controls and
                                                        procedures were not
effective as of December 31, 2021 in your amended Form 20-F.
       Exhibits 96.1, 96.2, 96.3, 96.4, 96.5 and 96.6
       Capital and Operating Cost, page EZ-8
 Scott Tozier
Albemarle Corporation
December 21, 2022
Page 2
2.       We note your response to comment 10 and our review found a variance
between your
         Magnolia operating costs as presented in Exhibit A and the Proved and
Probable operating
         costs from Exhibit B. Please correct as necessary or provide an
additional operating
         expense table with associated text in your report summary explaining
the variance in
         operating costs. In addition, please provide complete column and row
totals for all line
         items along with LOM totals. Please note combining columns is
acceptable, provided all
         numeric values are identical for all the combined columns and a
description regarding this
         practice is included in the text of the technical report summary.
Exhibits 96.1, 96.2, 96.3, 96.4, 96.5 and 96.6
Economic Analysis, page EZ-9

3.       We note your response to comment 11 and our review found the plant
feed flow, plant
         feed grade, and plant recovery are missing from your Magnolia and
Jordan property cash
         flow analysis. In addition, the Jordan property minority interest
costs do not reflect the
         ownership and an explanation may be necessary in the text. As noted
above, please
         provide complete column and row totals for all line items along with
LOM totals. Please
         note combining columns is acceptable, provided all numeric values are
identical for all the
         combined columns and a description regarding this practice is included
in the text of the
         technical report summary.
       Please contact Ken Schuler at 202-551-3718 or Craig Arakawa at
202-551-3650 with any
questions.



                                                              Sincerely,
FirstName LastNameScott Tozier
                                                              Division of
Corporation Finance
Comapany NameAlbemarle Corporation
                                                              Office of
Industrial Applications and
December 21, 2022 Page 2                                      Services
FirstName LastName
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