SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

Mail Stop 4631
December 16, 2009
 Mr. Russell Chenu Chief Financial Officer James Hardie Industries N.V. Atrium, 8
th Floor
Strawinskylaan 3077 1077 ZX Amsterdam, The Netherlands
 RE: Form 20-F for the fiscal  year ended March 31, 2009
  File No. 1-15240

Dear Mr. Chenu:
We have reviewed your response letter  dated December 2, 2009 and have the
following additional comment.  If you disagree with our comment, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary in your explan ation.  In our comment, we may ask you to
provide us with 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 re view 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 comment 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 20-F FOR THE YEAR ENDED MARCH 31, 2009

Item 18 - Financial Statements

Restricted Cash and Cash Equivalents, page F-9 and Restricted Cash and Cash
Equivalents – Asbestos, F-19

1. We have reviewed your response to prior comment 17 of our letter dated
November 4, 2009.  Your response indicates that cash and cash equivalents of the
AICF are reflected as restricted assets, as th e use of these assets is restricted to the
settlement of asbestos claims and paymen t of the operating costs of the AICF and
that you classify these amounts as a current  asset on the face of the consolidated
balance sheet since they are highly liquid.  On the face of your balance sheet as of

Mr. Russell Chenu
James Hardie Industries N.V. December 16, 2009 Page 2 of 2
March 31, 2009, you present current restrict ed cash and cash equivalents related
to asbestos in the amount of $45.4 milli on and current restri cted short-term
investments related to asbestos in the amount of $52.9 million, while your current
asbestos liability is $78.2 million.  Given your restricted current assets related to
asbestos are greater than your current as bestos liability, plea se tell us what
consideration you gave to presenting certain  amounts of restricted assets related to
asbestos as non-current assets.  In this regard, we note your intention to record
cash and cash equivalents between curre nt and non-current amounts in your
consolidated balance sheets  based on the current and non-current classification of
your estimated claims liability.

*    *    *    *
 Please respond to this comment within 10 business days, or tell us when you will
provide us with a response.  Please provide us with a response letter that keys your
response to our comment and provides any requested information.  Detailed letters
greatly facilitate our review.  Please file your supplemental response on EDGAR as a correspondence file.  Please understand that we may have additional comments after reviewing your response to our comment.
 You may contact Jay Ingram, Legal Bran ch Chief, at (202) 551-3397 if you have
any questions regarding legal or disclosure matters.  Please contact Jeffrey Gordon, Staff
Accountant, at (202) 551-3866 or, in his absence, Jeanne  Baker, Assistant Chief
Accountant at (202) 551-3691 if you have ques tions regarding comments on the financial
statements and related matters.

 Sincerely,
 Rufus Decker
 Accounting Branch Chief