SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

                                                                February 3, 2012
 Via E-mail

Mr. Russell Chenu Chief Financial Officer James Hardie Industries SE Europa House, Second Floor, Harcourt Center
Harcourt Street, Dublin 2, Ireland

 RE: James Hardie Industries SE
Form 20-F for the Year Ended March 31, 2011 Filed June 29, 2011 Form 20-F/A for the Year  Ended March 31, 2011
Filed July 14, 2011 File No. 1-15240

Dear Mr. Chenu:

We have reviewed your filing 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 this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us why in your response.
   After reviewing the information you provide  in response to these comments, we may
have additional comments.  Form 20-F for the Year Ended March 31, 2011

 General

 1. Where a comment below requests additional disclosures or other revisions to be made, please
show us in your supplemental response what th e revisions will look lik e.  These revisions
should be included in your future filings, in cluding your interim filings, if applicable.

Mr. Russell Chenu
James Hardie Industries SE February 3, 2012 Page 2
 Financial Statements

 Summary of Significant Acc ounting Policies, page 80

 Impairment of Long-Lived Assets, page 80

 2. We note your disclosures regarding impairment of  long-lived assets.  In the interest of
providing readers with a better insight into management’s judgments in accounting for long-
lived assets, including property and equipment and customer rela tionships intangible assets,
please disclose the following:
 How you group long-lived assets for impairment and your basis for that determination;
 How frequently you evaluate for the types of events and circumstances that may indicate
impairment;
 Sufficient information to enable a reader to  understand how you determine fair value; and
 The carrying value of any long- lived assets or asset groups for which the carrying value
is close to corresponding undiscoun ted cash flows or fair value.
 15. Commitment and Con tingencies, page 94

 ASIC Proceedings, page 94

 3. You disclosed that on December 17, 2010, you were ordered to pay 90% of the costs incurred
by AISC in respect of your appeal.  You also disclose in MD&A that you were ordered to
pay a portion of the costs for each of the first instance proceedings and appeal.  You
indicated that in light of the uncertainty su rrounding the amount of such costs, you have not
recorded any provisions for these costs at March 31, 2011.  Please clarify whether ASIC has
provided you with the amount of costs that they incurred.  You also disclose that losses and
expenses arising from the ASIC proceedings could have a material adverse effect on your
financial position, liquidity, resu lts of operations and cash flows.   If there is at least a
reasonable possibility that a loss exceeding amounts alrea dy recognized may have been
incurred for your ASIC matter, pl ease either disclose an estimate  (or, if true, state that the
estimate is immaterial in lieu of  providing quantified amounts) of  the additional loss or range
of loss, or state that such an estimate cannot be made. Please refer to ASC 450-20-50.
   We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.
In responding to our comments, please provi de a written statement from the company
acknowledging that:

 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

Mr. Russell Chenu
James Hardie Industries SE February 3, 2012 Page 3
  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

 the company 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.

You may contact Ernest Greene, Staff A ccountant at (202) 551-3733 or Jeanne Baker,
Assistant Chief Acc ountant at (202) 551-3691  if you have questions regarding these comments.

       S i n c e r e l y ,

/s/ Rufus Decker
         R u f u s  D e c k e r
       Accounting Branch Chief