A. M Castle & Co.

Larry A. Boik

Vice President-Finance & CFO

January 16, 2007

Mr. Carl Hiller

Branch Chief

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street NE

Washington, D.C. 20549-7010

Re:    A. M. Castle & Co.

      File No. 1-5415

Dear Mr. Hiller:

This letter responds to your letter of January 5, 2007 relating to A. M. Castle & Co.’s

(“Company” or “we”) Form 10-K filing for the fiscal year ended December 31, 2005, filed

on March 31, 2006 (the Form 10-K) and Form 8-K/A filed on November 7, 2006 and is

in furtherance of your ongoing review which originated with your letter of September 5, 2006.

This letter supplements our letters of October 4, 2006 and December 6, 2006 to provide

additional information and to address each of the comments in your January 5th letter.

Comment Responses

Our responses to the comments in your letter are identified by the same paragraph

numbers used in your letter.

 1. We note your response to prior comment 3, indicating you would prefer to

   remove the measure of gross material from your Statements of Operations,

  rather than report a measure that reflects all costs of sales, such as the

  costs of receiving. picking, storage, freight and DD&A, currently presented

  in separate line items below the margin metric. However, you explain that

   you would continue to report the non-GAAP measure in MD&A and

  selected quarterly data.

      3400 North Wolf Road, Franklin Park, Illinois 60131

       (847) 359-2576 Fax (847) 455-6930

        Email: lboik@amcastle.com

           United States Securities and Exchange Commission

                 January 16, 2007

                   Page 2

Please understand that the scenario under which you would remove the

margin measure, rather than recalculate after repositioning the relevant costs,

is under consideration because we believe that GAAP would require a more

comprehensive measure than is currently depicted. Therefore, although we

would not object if you remove the margin metric from your Statements of

Operations, if you disclose the measure as currently computed elsewhere in

the filing, you will need to include the disclosures required under Item 10(e) of

Regulation S-K. Based on your characterization, we would expect the most

comparable GAAP-based measure to which it would need to be reconciled to

be gross margin, reflecting all costs of sales, including the costs of

processing, receiving, picking, and DD&A and maintenance related to your

storage, warehouse and workshop facilities.

Please submit the draft disclosures that you would provide under this

scenario, and be sure to include the reasons management believes the

measure provides useful information that is not reflected in any GAAP

measure, as well as a balanced discussion of the most comparable GAAP-

based measure. It should be clear that disclosure is not precluded by the

guidance in Item 10(e)(1)(ii)(A) and (B) of Regulation S-K.

As previously stated, on a prospective basis, the Company will eliminate the “Gross

Material Margin” line item in its Statement of Operations presentation to bring this

matter to a conclusion prior to the preparation of our Annual Report for the year ended

December 31, 2006. Consistent with the presentation by other companies in the steel

service center industry, the Company will reflect a detailed “Costs and expenses”

section in its Statement of Operations following the “Net sales” line item. This section

will include the following components: “Cost of materials”, “Plant and delivery

expense”, “Sales, general and administrative expense” and “Depreciation and

amortization expense.” The definition of these line items will be consistent with their

historical definitions and they will include the same costs and expenses as they have in

prior years. The “Gross Material Margin” sub-total will no longer be reflected on the

Statement of Operations.

We have considered your guidance as indicated in your comment and have

reconsidered our future presentation of the referenced metric. Our supplemental

unaudited quarterly financial data, included in the footnotes to our financial statements,

and Management’s Discussion and Analysis section of the 10-K will also exclude the

use of “Gross Material Margin” in our future filings. In concert with your guidance, in

future filings, we will disclose in the quarterly financial data footnote to the financial

statements “Gross profit,” which will reflect “Net sales” less “Cost of materials ”, “Plant

and delivery expense”, and “Depreciation and amortization expense,” which in the

aggregate, includes all costs of materials, processing, picking, receiving, facility and

equipment maintenance, and DD&A in relation to our operations. A sample of this

proposed format for our Statement of Operations and for the quarterly financial data

footnote disclosure is attached as Schedule “A” to this letter.

          United States Securities and Exchange Commission

                 January 16, 2007

                  Page 3

     2.  We have read your response to prior comment four in which you explain

    that the pro forma adjustment described in point (e) of Note 2 relates to an

          additional "one time expense" that you will incur to document and assess

          internal controls.  Give your characterization of this adjustment, it does

          not appear to meet the criteria (ii) of Rule 11-02(b)(6) of Regulation S-X,

          since it would not ahve a continuing impact (i.e. it is not decribe[d] as a

          recurring charge). Please acknowledge your understanding of this

          requirement, and tell us whether you believe the difference would be

          sufficiently material to require a restatement of your pro forma

          presentation.

 You are correct in citing that our response in regards to the additional expense relating

 to the documentation and assessment of internal controls referred to these costs as

 being “one-time expense”. Our earlier response to you on this matter could have further

 elaborated on this point. Although there is a factually supportable cost (quotations and

 invoicing) associated with the work preformed by David Lewis Company to initially bring

 the internal control documentation of this formerly privately-held enterprise up to Section

 404 compliance, we should have elaborated on the continuing impact of that work.

 Specifically, the current year costs include the initial costs of creating internal control

 documentation, assessing those controls and performing a risk assessment for the

 acquired business. In subsequent years, a significant portion of such expense will

 remain as the Company annually must perform risk assessments, update its

 documentation of internal controls and regularly perform testing at the acquired

 business to support its own assessment of the effectiveness of its internal controls.

 Additionally, fees paid to our external auditors will increase due to the expanded scope

 of their required audit services as a result of this acquisition. Therefore, we believe that

 point (e) of Note 2 as filed in our Form 8-K/A does meet the criteria of Rule 11-02

 (b)(6)(ii) of Regulation S-X as a recurring expense.

 Notwithstanding the foregoing, we believe the amount of the costs relating to point (e) of

 Note 2 is not sufficiently material to warrant a restatement of our pro forma presentation

 as it represents less than 1.6% of the consolidated company’s pro forma net income as

 presented in the Company’s filing on Form 8-K/A filed on November 7, 2006.

 Finally, the Company acknowledges the following:

         w  The Company is responsible for adequacy and accuracy of the disclosure in

 the filing

  w  Staff comments or changes to disclosures in response to staff comments do not

      foreclose the Commission from taking any action with respect to the filing; and

          United States Securities and Exchange Commission

                 January 16, 2007

                  Page 4

      w The Company may not assert staff comments as a defense in any proceeding

      initiated by the Commission or any person under the federal securities laws of

      the United States

If the Commission wishes further explanation or information regarding the above please

   do not hesitate to contact the undersigned.

Sincerely,

/s/ Lawrence A. Boik

Vice President & Chief Financial Officer

 LAB:kar

 cc: Ms. Tracie Towner, United States Securities and Exchange Commission

Attachment “A”

A.M. Castle & Co.
Consolidated Statement of Operations
				Period Ended XXX, 200X
(dollars in thousands, except per share data)
Net Sales					$XX
Costs and Expenses:
Cost of materials (exclusive of depreciation shown below)					XX
Plant and delivery expense					XX
Sales, general and administrative expense					XX
Depreciation and amortization expense					XX
Operating income					XX
Interest expense, net					XX
Income before taxes and equity earnings of joint venture					XX
Equity in earnings of joint venture					XX
Net income					XX
Preferred dividends					XX
Net income applicable to common stock					$XX
Basic earnings per share					$XX
Diluted earnings per share					$XX
Dividends per common share					$XX
Footnote XX - Selected quarterly financial data (unaudited)
(dollars in thousands)
		First	Second	Third	Fourth
Year XXXX		Quarter	Quarter	Quarter	Quarter
Net Sales		$XX	$XX	$XX	$XX
Gross Profit (1)		XX	XX	XX	XX
Net income		XX	XX	XX	XX
Preferred dividends		XX	XX	XX	XX
Net income applicable to common stock		XX	XX	XX	XX
Net income per share - basic		XX	XX	XX	XX
Net income per share - diluted		XX	XX	XX	XX
(1)	Gross profit is net sales less the cost of materials, plant
	and delivery expense and depreciation and amortization expense.