SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

 May 4, 2012
  Via facsimile

Mr. Paul G. Boynton President and Chief Executive Officer Rayonier Inc. 1301 Riverplace Blvd. Jacksonville, FL 32207   RE:  Rayonier Inc.
Form 10-K for the Fiscal Ye ar Ended Decem ber 31, 2011
  Filed February 28, 2012   File No. 1-06780

Dear Mr. Boynton:
We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.
Item 1. Business, page 1

1. Under the "performance fibers" and "wood products" segments, please tell us how you
define "production capacity." Please tell us wh ether your calculations are consistent with
any industry-wide recognized measur es. We may have further comment.

Forest Resources, page 2

2. We note that you combine your Washington and New York timber holdings into the same
region, but we also note the difference in these sub-regions in growth rates, access to
mills and export markets.  Please tell us what  consideration you have given to breaking
out the Northern region operating data be tween Washington and New York.  We may
have further comment.

Mr. Paul G. Boynton
Rayonier Inc. May 4, 2012 Page 2
 3. We note your merchantable timber invent ory disclosure.  Please tell us what
consideration you have given to providing add itional detail, to the extent available to
management, regarding inventory data broken out by age of trees.  We may have further
comment.

4. Please tell us why you do not disclose opera ting data regarding 2011 harvest volumes by
region.  In addition, please tell us what consideration you have given to disclosing
anticipated 2012 harvest volume.

Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 20

5. In future filings, please expand your disclo sures regarding the CSE to discuss the
expected effects on your operations.  We note that you will add 190,000 metric tons of
cellulose specialties capacity, while losing 260,000 metric tons of absorbent materials
capacity.  Your expanded disclosure should incl ude your expectations of how this change
affects your expenses as well as revenues.

6. We note your disclosure on page 21 that ti mber is also marketed through log supply
agreements. Please tell us the approximate amount of timber that is covered by such
supply commitments in 2012. We may have further comments.

7. We note your disclosure on page 25 regarding sales data with respect to your forest
resources segment. Please tell us what cons ideration you gave to breaking out your sales
data between pulpwood and sawtimber.   We may have further comment.
  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.     In responding to our comments, please provi de a written statement from the company
acknowledging that
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Mr. Paul G. Boynton
Rayonier Inc. May 4, 2012 Page 3
 You may contact William Demarest, Staff Acco untant, at (202) 551-3432 or me at (202)
551-3486 with any questions on the financial stat ements or related matters.  Please contact
Folake Ayoola, Staff Attorney at (2 02) 551- 3673 with any other questions.
         S i n c e r e l y ,           /s/ Daniel L. Gordon          Daniel L. Gordon         B r a n c h  C h i e f