SecProbe.io

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                               [WORTHINGTON LOGO]

December 1, 2004

Rufus Decker
Accounting Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C.  20549-0510

Re:  Comment letter dated November 16, 2004, File No. 1-8399

Dear Mr. Decker:

This letter is in response to your comments related to the Form 10-K for the
period ended May 31, 2004 and the Form 10-Q for the quarter ended August 31,
2004 of Worthington Industries, Inc. (the "Company"). We take very seriously our
responsibility to provide complete and accurate disclosures to the users of the
financial information included in our filings. In preparing this information, we
review the disclosure requirements established by the various governing bodies
and reach a conclusion as to what is appropriate. We also consult with our
independent auditors and our legal counsel. We feel this process ensures that
what we report is in material compliance with the requirements. We will continue
to employ this process in monitoring the changing disclosure requirements to
ensure that we are in compliance. The following information consists of our
responses to your letter and each response has been numbered to match the
comments in your letter.

SEGMENT OPERATIONS

2.   As disclosed in the segment footnote, the "Other" category includes
     corporate related items, results of immaterial operations and income and
     expense not allocable to the reportable segments. The operating loss for
     this "Other" category was $1.0 million in fiscal 2004 compared to a loss of
     $10.0 million for fiscal 2003. This $9.0 million improvement is mainly due
     to a $4.3 million and a $2.7 million improvement in the Worthington Machine
     Technology ("WMT") and the Steelpac operations, respectively. In fiscal
     2003, management decided that WMT would stop servicing external customers
     and focus only on the internal needs of Worthington Industries. This
     decision resulted in the elimination in fiscal 2004 of the $2.6 million
     operating loss recorded in fiscal 2003 and also in fiscal 2003 we recorded
     a $1.7 million reserve for severance and other items. The fiscal 2004
     operations of Steelpac improved by $2.0 million over fiscal 2003. In
     addition, $0.7 million of equipment was written-off by Steelpac in fiscal
     2003.

     In future filings, significant fluctuations in operating income (loss) for
     the "Other" category will be discussed in the segment MD&A.

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CONTRACTUAL OBLIGATIONS AND COMMERCIAL COMMITMENTS

3.   a.  In future filings, the table of contractual cash obligations will
         include estimated interest payments on debt. The estimated interest
         expense for our debt for the periods reviewed is:

<TABLE>
<CAPTION>
AS OF MAY 31, 2004                                   PAYMENTS DUE BY PERIOD
                                     -----------------------------------------------------
                                               LESS THAN    1 - 3       4 - 5       AFTER
         IN MILLIONS                 TOTAL      1 YEAR      YEARS       YEARS      5 YEARS
                                     -----      ------      -----       -----      -------
<S>                                  <C>        <C>         <C>         <C>        <C>
Estimated interest payments
  on long-term debt                  $ 78.6      $ 19.9     $ 29.6      $ 19.4       $ 9.7
</TABLE>

<TABLE>
<CAPTION>
AS OF AUGUST 31, 2004                                PAYMENTS DUE BY PERIOD
                                     -----------------------------------------------------
                                               LESS THAN    1 - 3       4 - 5       AFTER
         IN MILLIONS                 TOTAL      1 YEAR      YEARS       YEARS      5 YEARS
                                     -----      ------      -----       -----      -------
<S>                                  <C>        <C>         <C>         <C>        <C>
Estimated interest payments
  on long-term debt                  $ 73.7      $ 19.9     $ 29.6      $ 19.4       $ 4.8
</TABLE>

     b.  We plan to fund our pension obligations based upon the annually
         calculated minimum funding requirements of ERISA. This calculation is
         zero for fiscal 2005. Therefore, there is no planned amount to
         disclose. In addition, the Company does not have any post-retirement
         benefit obligations.

NOTE A. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

General
-------

4.   In the future, we will include in our summary of significant accounting
     policies the following disclosure:

         Shipping and Handling Fees and Costs: Shipping and handling fees billed
         to customers are included in net sales and shipping and handling costs
         incurred by the Company are included in cost of goods sold.

Property and Depreciation
-------------------------

5.   In the future, we will include in our summary of significant accounting
     policies under the Property and Depreciation heading the following
     disclosure:

         Buildings and improvements are depreciated over 10 to 40 years and
         machinery and equipment over 3 to 20 years.

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NOTE B. SHAREHOLDERS' EQUITY

6.   We have not disclosed the reclassification adjustments for other
     comprehensive income because there has either not been an adjustment or any
     such adjustment has been immaterial. The only reclassification adjustment
     for fiscal 2004 was $248,000 related to the cash flow hedges. If these
     adjustments become material in the future, we will disclose them as
     required by SFAS 130.

7.   Based on the amount of zinc and natural gas commodity usage hedged, the
     estimated net gains reported in other comprehensive income at May 31, 2004
     expected to be reclassified into net earnings within the next twelve months
     was $1,653,000. We will disclose this information in our next filing on
     Form 10-K.

NOTE H. INDUSTRY SEGMENT DATA

8.   Net sales for the Canadian operations have not been separately disclosed
     because they only comprise approximately 1% of total consolidated sales. In
     our next filing on Form 10-K, we will adjust our geographic disclosure as
     follows:

Net sales for the years ended May 31 for our locations grouped in the following
geographic areas are as follows:

<TABLE>
<CAPTION>
         IN THOUSANDS                2004              2003              2002
                                     ----              ----              ----

<S>                               <C>               <C>               <C>
United States                      2,259,609         2,103,491         1,654,976
Canada                                24,680            24,639            18,912
South America                              -                 -             4,600
Europe                                94,815            91,760            66,473
                                  ----------        ----------        ----------
   TOTAL                          $2,379,104        $2,219,890        $1,744,961
                                  ==========        ==========        ==========
</TABLE>

Long-lived assets grouped in the same manner are as follows:

<TABLE>
<CAPTION>
         IN THOUSANDS                2004              2003              2002
                                     ----              ----              ----
<S>                               <C>               <C>               <C>
United States                     $  528,596        $  712,530        $  739,169
Canada                                 2,552             3,139             3,426
South America                              -                 -                 -
Europe                                24,246            27,375            24,001
                                  ----------        ----------        ----------
   TOTAL                          $  555,394        $  743,044        $  766,596
                                  ==========        ==========        ==========
</TABLE>

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In responding to your comments, we acknowledge that:

-    we are responsible for the adequacy and accuracy of the disclosure in our
     filings;

-    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

-    we 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.

We believe the above explanations have been responsive to your comments. Should
you need further information, please contact Richard Welch at 614-840-3437.

Sincerely,

/s/ John S. Christie
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John S. Christie
President and Chief Financial Officer

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