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June 8, 2023
Theresa E. Wagler
Executive Vice President and Chief Financial Officer
Steel Dynamics, Inc.
7575 West Jefferson Blvd
Fort Wayne, IN 46804
Re:Steel Dynamics, Inc.
Form 10-K for the Year Ended December 31, 2022
Filed February 28, 2023
Form 8-K Filed April 21, 2023
File No. 000-21719
Dear Theresa E. Wagler:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 45
1.Regarding your presentation of operational working capital, please tell us what
consideration you gave to including a discussion of working capital and presenting a
reconciliation of the differences between operational working capital and working capital
in accordance with Item 10(e)(1)(B) of Regulation S-K.

 FirstName LastNameTheresa E. Wagler
 Comapany NameSteel Dynamics, Inc.
 June 8, 2023 Page 2
 FirstName LastName
Theresa E. Wagler
Steel Dynamics, Inc.
June 8, 2023
Page 2
Form 8-K Filed April 21, 2023
Exhibit 99.1
2.We have the following comments regarding the presentation of your non-GAAP measures
adjusted net income and adjusted earnings per share:
•Please present a reconciliation of the differences between the non-GAAP financial
measures with the most directly comparable GAAP financial measures as required by
Item 10(e)(1)(B) of Regulation S-K.  The reconciliations should present income taxes
as a separate adjustment and your disclosure should clearly explain how the tax
effects of non-GAAP adjustments are calculated, in accordance with Question 102.11
of the Division of Corporation Finance’s Compliance and Disclosure Interpretations
on Non-GAAP Financial Measures; and
•Please explain to us how you determined the adjustments for (1) additional
performance-based companywide special compensation awarded to all non-
executive, eligible team members in recognition of your annual performance and (2)
costs associated with construction and startup of your Texas Flat Roll Steel Mill are
appropriate based on the guidance in Question 100.01 of the Division of Corporation
Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures, or tell us how you plan to revise your non-GAAP financial measures in
future filings.
3.We note that your reconciliation of net loss to EBITDA includes a reconciling item related
to noncontrolling interest.  Please be advised that Question 103.01 of the Division of
Corporation Finance’s Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures indicates that EBITDA is defined as “earnings before interest, taxes,
depreciation and amortization.”  Please revise the non-GAAP measure you present as
EBITDA to only include adjustments for items contemplated by its acronym or revise the
title of the non-GAAP measure you present to convey the additional adjustment.
4.Please describe to us the nature of the specific costs included in the non-GAAP
adjustments related to unrealized (gains) losses and inventory valuation you presented in
your Adjusted EBITDA reconciliation.  In addition, please explain how you determined
that these adjustments are appropriate based on the guidance in Question 100.01 of the
Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-
GAAP Financial Measures.

 FirstName LastNameTheresa E. Wagler
 Comapany NameSteel Dynamics, Inc.
 June 8, 2023 Page 3
 FirstName LastName
Theresa E. Wagler
Steel Dynamics, Inc.
June 8, 2023
Page 3
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Jeffrey Gordon at 202-551-3866 or Hugh West at 202-551-3872 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing