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CORRESP
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JOY GLOBAL INC.

100 E. Wisconsin Ave., Suite 2780
 Milwaukee,
WI 53202

        March
21, 2005

VIA EDGAR SUBMISSION

Securities and Exchange
Commission Division
of Corporate Finance
450 Fifth Street, NW.

Washington, D.C. 20549
Attention:
 Mary Beth Breslin

Re:
Joy Global Inc.Form
      S-3 filed December 23, 2004
      (SEC File No. 333-121569)

      Joy Global
Inc.
      Form
10-K for the year ended October 30, 2004 and related filings
      (SEC File No. 001-09299)

      Joy
Global Inc.Form
      10-Q for the quarter ended January 29, 2005
      (SEC File No. 001-09299)

      Joy
Global Inc.Form
      8-K filed December 16, 2004
      (SEC File No. 001-09299)

Ladies and Gentlemen:

        On
behalf of Joy Global Inc. (the “Company”) and in response to the letter (the
“Comment Letter”) dated March 10, 2005 from the staff of the Securities and
Exchange Commission (the “Staff”) to the Company, please find below our
responses to the Comment Letter.

        The
numbered paragraphs below set forth the Staff’s comments from the Comment Letter (in
bold type), together with the Company’s responses (in ordinary type), and correspond
to the numbered paragraphs in the Comment Letter.

Form S-3

Exhibits

1.

Please
file a currently dated consent with the amendment to be declared           effective.

The Company
confirms that it will file a currently dated consent as requested.

Exhibit 5.1

               2.

               We note your response to comment 10. Please supplementally confirm that all
               initial purchasers of securities  registered under the registration
               statement, and all subsequent transferees of those securities from those
               initial purchasers or their transferees, may rely on the opinion.
               Alternatively, please revise the opinion to  remove the limiting
               language.

The Company
confirms that all initial purchasers of securities registered under the registration
statement, and all subsequent transferees of those securities from those initial
purchasers or their transferees, may rely on the opinion.

Form 10-Q for Quarter
Ended January 29, 2005

Part II

Item 4. Controls and
Procedures

               3.

               We note your disclosure that your CEO and CFO concluded that your disclosure
               controls and procedures were  effective as of October 30, 2004, rather
               than as of the end of the period covered by this quarterly report.
               Please amend your report to disclose management’s conclusion as to the
               effectiveness of your disclosure  controls and procedures as of January
               29, 2005.

Pursuant to
the Staff’s comment, the Company proposes to revise Item 4 of its Form 10-Q as shown
in the attached Exhibit A.

               4.

               We note your disclosure that your “Chief Executive Officer and Chief
               Financial Officer have concluded that…  [y]our disclosure controls
               and procedures are effective in recording, processing, summarizing and
               reporting, on  a timely basis, information required to be disclosed by
               [you] in the reports that [you] file or submit under  the Exchange
               Act.” Revise to clarify, if true, that your officers concluded that your
               disclosure controls and  procedures are also effective to ensure that
               information required to be disclosed in the reports that you file  or
               submit under the Exchange Act is accumulated and communicated to your
               management, including your chief  executive officer and chief financial
               officer, to allow timely decisions regarding required disclosure. See
               Exchange Act Rule 13a-15(e).

Pursuant  to
the Staff’s comment, the Company proposes to revise Item 4 of its Form 10-Q as shown
in the attached Exhibit A.

               5.

               Please revise the language used in your disclosure concerning changes in your
               internal control over financial  reporting to indicate whether there was
               any change to your internal control over financial reporting that has
               materially affected, or that is reasonably likely to materially affect, your
               internal control over financial  reporting, consistent with the language
               used in amended Item 308(c) of Regulation S-K.

Pursuant to the Staff's comment, the Company proposes to revise Item 4 of its Form 10-Q as shown in the attached
Exhibit A.

      ¤¤¤

The Company
hopes that the foregoing has been responsive to the Staff’s comments.

      If you
have any questions related to this letter, please contact either me at 1-414-319-8512 or
Keith Crow of Kirkland & Ellis at 1-312-861-2181. Please send any further comments
via facsimile to me at 1-414-319-8520 and Keith Crow at 1-312-861-2200.

     Sincerely,

/s/ Oren B. Azar

Oren B. Azar

Associate General Counsel and Secretary

cc:

Keith S. Crow, Esq.
John Jennings, Esq.