SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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April 21, 2005
via U.S. mail

Joyce E. Mims, Esq.
Vice President & General Counsel
Ryerson Tull, Inc.
2621 West 15th Place
Chicago, Illinois 60608

RE:	Ryerson Tull, Inc.
	Ryerson Tull Procurement Corporation
	Form S-3/A filed April 5, 2005
	File No. 333-122316

	Response Letter dated April 5, 2005

Dear Ms. Mims:

      	We have limited our review of the above filing  and
response letter and have the following comments.  If you disagree,
we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form S-3
Selling Securityholders, page 59
1. In footnote 11, you indicate that Deephaven Market Neutral
Trading, LP is an "underwriter" of the notes.  Is this entity
selling
notes and shares pursuant to the registration statement?  If so,
please revise the Selling Securityholder table to include this
information or advise us as to why this is not necessary. We may
have
further comments.
2. Please clarify the disclosure in footnote 15 so that you
plainly
state, as done in other footnotes, if the selling securityholder
is
an affiliate of a broker-dealer.
Plan of Distribution, page 63
3. We note the disclosure in the footnotes to the Selling
Securityholder table that identifies certain of the selling
securityholders as underwriters.  Please provide disclosure in the
Plan of Distribution section of the prospectus that specifically
identifies as underwriters the registered broker-dealers
referenced
in the footnotes to the Selling Securityholder table, unless such
broker-dealers received their notes and shares as compensation for
underwriting activities.
Closing Comments
	Please amend the above filing in response to these comments.
You may wish to provide us with marked copies of the amendment to
expedite our review.  Please furnish a cover letter with your
amendment that keys your responses to our comments and provides
any
requested supplemental information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that :

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any
person
under the federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	Please direct all questions relating to the above to Mellissa
Campbell Duru, at (202) 942-1930, or in her absence, to Tangela
Richter, Legal Branch Chief at (202) 942-1837.  Direct all
correspondence to the following ZIP code:  20549-0405.
								Sincerely,

								H. Roger Schwall
								Assistant Director

via facsimile
Phillip J. Niehoff
Mayer, Brown, Rowe & Maw LLP
 (312) 706-8180

cc:	H.R. Schwall
      T.Richter
      M.Duru
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Ryerson Tull, Inc., et al.
April 21, 2005

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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