0001193125-14-298569.txt : 20141008 0001193125-14-298569.hdr.sgml : 20141008 20140806173752 ACCESSION NUMBER: 0001193125-14-298569 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140806 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: 312 292-5014 MAIL ADDRESS: STREET 1: 227 W. MONROE ST., 27TH FLOOR CITY: CHICAGO STATE: IL ZIP: 60606 CORRESP 1 filename1.htm Acceleration Request

RYERSON HOLDING CORPORATION

227 W. Monroe, 27th Floor

Chicago, IL 60606

August 6, 2014

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Ryerson Holding Corporation

Registration Statement on Form S-1

File No. 333-164484

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Ryerson Holding Corporation (the “Company”) hereby respectfully requests that the effectiveness of the above-captioned Registration Statement on Form S-1 (as amended to date, the “Registration Statement”) be accelerated to August 7, 2014 at 4:00 p.m., Eastern Daylight Time, or as soon as practicable thereafter. Under separate cover, you will receive today a letter from the managing underwriters of the proposed offering joining in the Company’s request for acceleration of the effectiveness of the Registration Statement.

The Company hereby acknowledges that:

 

  •  

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 

  •  

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the accuracy and adequacy of the disclosure in the Registration Statement; and

 

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the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please confirm that the Registration Statement has been declared effective by telephoning Cristopher Greer, Esq. of Willkie Farr & Gallagher LLP at (212) 728-8214. Comments with respect to this request or the Registration Statement may be directed to Mr. Greer by telephone or facsimile at (212) 728-9214.

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

Sincerely,

 

RYERSON HOLDING CORPORATION
By:   /s/ Edward J. Lehner
Name:   Edward J. Lehner
Title:   Chief Financial Officer

 

cc: Cristopher Greer, Esq.

Jared Nicholson, Esq.

[Signature Page to Acceleration Request]