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      Castle Response to SEC Ltr 6-9-05

                        July
      6,
      2005

    United
      States
      Securities and

    Exchange
      Commission

    Division
      of
      Corporation Finance

    Washington,
      D.C.
      20549-0405

    Attention:
      Ms. Jill
      Davis, Branch Chief

    RE:   A.
      M. Castle &
      Co.

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

    Filed
      March 16, 2005

    File
      No. 1-5415

    Ladies
      and
      Gentlemen:

    This
      letter is in
      response to your letter dated June 9, 2005 commenting on the Form 10-K for
      Fiscal Year Ended December 31, 2004 (the "2004 10-K") of A. M. Castle & Co.
      ("Castle" or the "Company"). For purposes of referencing our responses, the
      comments from your letter have been included prior to each
      response.

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

    Balance
      Sheet,
      page 19

    1. Please
      revise your inventory presentation to separately report the value of inventory
      consigned to others at each balance sheet date. See Question 2 of SAB Topic
      13-A-2.

    RESPONSE.
      Based on
      its LIFO valuation of inventory, the value of Castle’s consigned inventory is
      approximately $0.5 million, or 0.34% of its $135 million book inventory at
      December 31, 2004.

    The
      Company
      maintains consignment relationships with nine customers. For all nine of these
      consignment arrangements, revenue is recognized when the inventory is consumed
      by the customer, which is also the point when title passes and the Company
      has
      no further obligations to the customer.

    Question
      2 of SAB
      Topic 13-A-2 states that åif title to the goods has passed but the substance of
      the arrangement is not a sale, the consigned inventory should be reported
      separately from other inventory in the consignor’s financial statements as
åinventory consigned to othersæ or another appropriate caption.

    The
      Company
      maintains title to the consigned inventory until a sale has occurred and,
      accordingly, Question 2 of SAB Topic 13-A-2 is not applicable to
      the Company’s consignment arrangements. We have considered this guidance,
      the immaterial nature of consigned

    July
      6,
      2005

    A.
      M. Castle & Co.

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

    Filed
      March 16,
      2005

    File
      No.
      1-5415

    Page
      2

    inventory
      and the
      related sales to the Company’s consolidated inventory and net sales, and have
      determined, therefore, that separately reporting the value of inventory
      consigned to others on the balance sheet would not enhance the Company’s
      disclosure.

    Therefore,
      Castle
      does not believe that it is necessary to update or amend its 2004 10-K in
      response to the staff’s comment. Castle, as part of its preparation of its
      financial statements in any report or document filed with the Commission, will
      continue to assess the value of its consigned inventory and, if such value
      in
      the future becomes material to Castle’s inventory presentation, Castle will
      include appropriate disclosure in its financial statements in any such future
      report or document.

    2. Include
      in Management’s Discussion and Analysis, a more detailed analysis of the revenue
      recognized in each period from sales of consigned inventory.

    RESPONSE.
      Due to
      the fact that consigned inventories generally turn at a faster rate than
      Castle’s inventory as a whole, net sales of consigned inventory in 2004 was
      approximately $9 million, or 1.2% of total consolidated sales reported for
      the
      year.

    Specifically,
      on
      page 15 of the Company’s Annual Report on Form 10-K under the caption åCritical
      Accounting Policiesæ in Management’s Discussion and Analysis (åMDAæ) a section
      on revenue recognition states clearly that revenues of consigned inventory
      are
      not recorded until the customer has consumed the product from the consigned
      inventory and title has passed. Since, the amount of sales from consignment
      arrangements is 1.2% of net sales, in our opinion, a more detailed analysis
      of
      revenue recognized from consigned inventory is not pertinent in understanding
      the Company’s consolidated business or year-end results.

    Given
      the facts
      relating to the materiality of the amount of inventory and sales associated
      with
      consignment arrangements, the Company does not believe that an amendment to
      its
      2004 10-K expanding the discussion of revenue in the MDA is
      necessary.

      Castle,
        as part of
        its preparation of its Management’s Discussion and Analysis in any report or
        document filed with the Commission, will continue to assess its policies
        regarding revenue recognition generally and for its consigned inventory and,
        if
        such policies in the future would require additional disclosure or analysis,
        Castle will include appropriate disclosure or analysis in its Management’s
        Discussion and Analysis in any such future report or
        document.

    For
      the reasons
      stated in its responses above, Castle does not believe that it is necessary
      to
      revise its disclosure or amend its 2004 10-K and we respectfully request the
      staff to reconsider its request in light of this response letter.

        July
          6,
          2005

      A.
        M. Castle &
        Co.

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

      Filed
        March 16,
        2005

      File
        No.
        1-5415

      Page
        3

    In
      closing, Castle
      acknowledges that it has responsibility for the adequacy and accuracy of the
      disclosure in its 2004 10-K. Castle furthermore understands and acknowledges
      that staff comments or changes to disclosure in response to staff comments
      do
      not foreclose the Commission from taking any action with respect to the 2004
      10-K and that Castle 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.

    Hopefully
      this
      letter sufficiently responds to the staff’s comments and has brought this matter
      to a successful conclusion. Please feel free to contact me at (847) 349-2576
      should you have any questions about this response letter.

    Very
      truly yours,

    /s/
      Lawrence A. Boik

                                                         Vice
      President -
      Finance & CFO

    cc: Ms.
      Gabrielle Malits, Staff Accountant

    Division
      of Corporation Finance

    United
      States Securities and

      Exchange Commission

    Washington,
      D.C.
      20549-0405