0000899140-17-000034.txt : 20170215 0000899140-17-000034.hdr.sgml : 20170215 20170113173207 ACCESSION NUMBER: 0000899140-17-000034 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20170113 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Ryerson Holding Corp CENTRAL INDEX KEY: 0001481582 STANDARD INDUSTRIAL CLASSIFICATION: WHOLESALE-METALS SERVICE CENTERS & OFFICES [5051] IRS NUMBER: 261251524 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 227 W. MONROE ST., 27TH FLOOR CITY: CHICAGO STATE: IL ZIP: 60606 BUSINESS PHONE: 312 292-5000 MAIL ADDRESS: STREET 1: 227 W. MONROE ST., 27TH FLOOR CITY: CHICAGO STATE: IL ZIP: 60606 CORRESP 1 filename1.htm
RYERSON HOLDING CORPORATION
227 West Monroe Street
27th Floor
Chicago, Illinois 60606
January 13, 2017

via EDGAR


Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C.  20549
Attention: Donald E. Field
 
 
 
 Re:
 
Ryerson Holding Corporation (CIK No. 0001481582) (the “Registrant”)
 
 
Registration Statement on Form S-3 (Commission File No. 333-215381)
 
 
(the “Registration Statement”)
 
Dear Mr. Field:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned, on behalf of the Registrant, requests acceleration of the effective date of the Registration Statement to 2:00 p.m., Eastern Time, on Wednesday, January 18, 2017, or as soon as practicable thereafter.

The accuracy and adequacy of the disclosure in the referenced filing is the responsibility of the Registrant. The Registrant acknowledges to the Commission that should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing, that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosures in the filing and that the Registrant may not assert staff comments and this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The cooperation of the staff in meeting the timetable described above is very much appreciated.

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Should you have any questions regarding any of the foregoing, please do not hesitate to contact me at (312) 292-5000 or Cristopher Greer of Willkie Farr & Gallagher LLP, our legal counsel, at (212) 728-8000.
 
 
 
 
 
 
Sincerely,
 
 
 
/s/ Erich S. Schnaufer       
 
 
Erich S. Schnaufer
Authorized Officer
 

cc:  Cristopher Greer, Willkie Farr & Gallagher LLP