January 3, 2006


Mr. Donald J. Gallagher
Chief Financial Officer
Cleveland-Cliffs Inc.
1100 Superior Avenue
Cleveland, Ohio  44114-2589




	Re:	Cleveland-Cliffs Inc.
		Form 10-K for Fiscal Year Ended December 31, 2004
Filed February 22, 2005
      Response Letter Dated December 20, 2005
      File No. 1-08944




Dear Mr. Gallagher:

      We have reviewed your response letter and have the following
comments.  We have limited our review of your filing to those
issues
we have addressed in our comments.  Please provide a written
response
to our comments.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments

Form 10-K for the Fiscal Year Ended December 31, 2004

Statement of Consolidated Cash Flows, page 59

1. We have considered your response to our prior comment number
two.
Please disclose the following with regard to your trading
securities
in future filings:

* The portion of trading gains and losses for the period that
related
to trading securities still held at the reporting date, as
required
by Statement of Financial Accounting Standards (SFAS) Number 115,
paragraph 21(e).

* Quantitative and qualitative disclosures about market risk with
regard to instruments entered into for trading purposes, as
required
by Regulation S-K, Item 305(a).

*  The disclosures for marketable securities required by
Regulation
S-X, Rule 5-02(2).

* It appears that cash inflows and outflows from your trading
securities should be reported on a gross basis in your Statement
of
Cash Flows.  Refer to SFAS 102, paragraph 29.

* Additional discussion with regard to your trading securities to
enable investors and other users to assess your financial
condition
and future cash flows from operations, as required by Regulation
S-K
Item 303(a) and Financial Reporting Codification Section 501.01
and
501.13.b.1.  In particular, address your trading objectives and
describe in greater detail the types of securities you are
trading.

Closing Comments

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	 You may contact Gary Newberry at (202) 551-3761, or Sandra
Eisen at (202) 551-3864, if you have questions regarding comments
on
the financial statements and related matters.  Please contact me
at
(202) 551- 3684 with any other questions.

								Sincerely,



								April Sifford
								Branch Chief
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Mr. Donald J. Gallagher
Cleveland-Cliffs Inc.
January 3, 2006
page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, N.E.
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
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