SecProbe.io

November 25, 2013

Via E -mail
Tony M. Shelby
Chief Financial Officer
LSB Industries, Inc.
16 South Pennsylvania Avenue
Oklahoma City, OK  73107

Re: LSB Industries, Inc.
 Form 10-K for the Year Ended December 31, 2012
Filed February 28, 2013
File No. 1 -7677

Dear Mr. Shelby :

We have reviewed your filing an d 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 prov iding the requested
information  or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumsta nces, please  tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Year Ended December 31, 2012 Compared to Year Ended December 31, 2011, page 42

Other, page 44

1. In comment one of our letter dated December 3, 2012 regarding our review of your 2011
Form 10 -K, we asked that you revise your disclosures in future filings to discuss the
business reasons for material changes in amounts presented under the “other ” caption .
While we note that additional disclosures were provided, the explanations provided do
not appear to provide sufficient detail to enable the reader to understand the reasons for
fluctuations in the amounts presented .  For example, you indicate o n page 44 that the
decrease in general corporate expenses and other business operations, net, primarily
relates to the increase in sales.  I t is not inherently clear why an increase in sales would
result in a decrease in general corporate expense.  It is a lso unclear how significantly the

Tony M. Shelby
LSB Industries, Inc.
November 25, 2013
Page 2

 increase in personnel costs offset the expenses incurred only in 2011 related the
modification of the secured term loan and debenture conversion.  Please supplementally
show us how you will revise your future filings accor dingly.

Consolidated Financial Statements , page F -1

2. Acquisition of Working Interests in Natural Gas Properties, page F -15

2. Please tell us how you considered the need to provide the disclosures described in ASC
932-235-50-1A and 50 -1B or alternatively t ell us where you have provided this
information  in your financial statements .

3. Since it appears that you have not historically engaged in natural  gas producing activities,
we believe that your disclosures regarding these activities could be enhanced to imp rove
transparency for investors.  Please show us how you will revise your future filings to
address the following:
 Disclose, if true, that you used the proportionate consolidation method describe in
ASC 810-10-45-14 to account for your acquisition of these  working interests;
 Explain what the acquisition of a working interest entails, including a description
of the rights and responsibilities you received in connection with this transaction.
For example, it is unclear from your disclosures how the differen ce between the
9.7% working interest acquired and the 7.7% net revenue interest acquired affects
your accounting for natural  gas producing activities ; and
 Describe the methods you used to determine the estimated fair values of the assets
acquired and liab ilities assumed.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require .  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 t he disclosures they have made.

In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United
States.

Tony M. Shelby
LSB Industries, Inc.
November 25, 2013
Page 3

 You may contact Lisa Etheredge, Staff Accountant,  at (202) 551 -3424  or me at (202)
551-3768  if you have questions.

Sincerely,

 /s/ John Cash

John Cash
Accounting Branch Chief