SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

                                                               January 9, 2013

Via E -mail
Mr. Russell Chenu
Chief  Financial Officer
James Hardie Industries plc
Europa House, Second Floor, Harcourt Center
Harcourt Street, Dublin 2, Ireland

RE: James Hardie Industries plc
Form 2 0-F for the  Year Ended March  31, 2012
Filed July 2 , 2012
Form 6 -K
Filed November 16, 2012
File No. 1-15240

Dear Mr. Chenu :

We have reviewed your filing s 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 ten business days by providing the requested
information, or by ad vising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumstances, 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, 2012

General

1. Where a comment below requests additional disclosures or other revisions to be made, please
show us in your supplemental response what the revisions will look like.  These revis ions
should be included in your future filings, including your interim filings, if applicable.

Mr. Russell Chenu
James Hardie Industries plc
January 9, 2013
Page 2

 Management’s Discussion and An alysis, page 83

Year Ended 31 March 2012 Compared to Year Ended 31 March 2011, page 89

Income Tax Benefit (E xpense), page  93

2. When you present or discuss changes between periods in a non -GAAP financial measure as
an amount or percentage, such as but not limited to your discussion of the effective tax rate
of earnings excluding asbestos, asset impairments , and tax adjustments, please ensure that
you do so in the same manner with the comparable GAAP financial measure.  Refer to Item
10(e) of Regulation S -K.

Liquidity and Capital Resources, 103

General

3. Since your foreign operations appear to be significa nt, please disclose the following:
 The amount of cash and short -term investments held by foreign subsidiaries as compared
to your total amount of cash and short -term investments as of year -end;
 You would be required to accrue and pay taxes to repatriate these funds and you do not
intend to repatriate them, if true; and
 Quantify the amount of cash and short -term investments held by foreign subsidiaries
where the funds are not readily convertible into other foreign currencies, including U.S.
dollars.  Pleas e also explain the implications of any such restrictions upon your liquidity.
Refer to Item 303(a)(1) of Regulation S -K, SEC Release 33 -8350 Section IV and Financial
Reporting Codification 501.06.a.

Financial Statements

Notes to the Financial Statement s

Note 9.  Long -Term Debt, page 129

4. You disclosed that you were in compliance with all debt covenants at March 31, 2012.
Please disclose the specific terms of these debt covenants with any required ratios/amounts.
Please disclose the actual ratios/amou nts as of each reporting date for any material debt
covenants for which it is reasonably likely that you will not be able to meet.  Please also
consider showing the specific computations used to arrive at the actual ratios/amounts with
corresponding reconc iliations to US GAAP amounts.   See Sections I.D and IV.C of the SEC
Interpretive Release No. 33 -8350 and Compliance and Disclosures Interpretation 102.09
which is available on our website at
http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm .

Mr. Russell Chenu
James Hardie Industries plc
January 9, 2013
Page 3

 Form 6 -K Filed November 16, 2012

Exhibit 99.2

5. You present non -GAAP forward -looking information, including net operating profit
excluding asbestos and earnings excluding as bestos, ASIC expenses , and tax adjustments.
Please present the most directly comparable GAAP financial measures and provide a
quantitative reconciliation of the differences between the non -GAAP and GAAP financial
measures, to the extent available without unreasonable efforts.  Refer to Item 100(a) of
Regulation G.

Exhibit 99.3

6. You present operating profit before income taxes and net operating profit.  You include net
interest (expense) income and other income (expense) in your determination of operating
profit before income taxes.  Your Form 20 -F for the year ended March 31, 2012 as well as
the financial statements provided in Exhibit 99.5 of this Form 6 -K present an operating
income line item which excludes interest expense, interest income, and other in come
(expense).  In this regard, please tell us how you determined it was appropriate to include net
interest (expense) income and other income (expense) in your determination of operating
profit before income taxes in the financial information provided in  Exhibit 99.2.  Please also
tell us what consideration you gave to changing the description of the line item currently
described as EBIT to operating income to be consistent with the financial statements
provided in your Form 20 -F for the year ended March 31, 2012 as well as the financial
statements provided in Exhibit 99.5 of this Form 6 -K.

7. You present a full non -GAAP balance sheet, statement of operations, and statement of cash
flows.  Please revise your presentation to provide relevant information to in vestors without
providing full non -GAAP financial statements.  For additional guidance, please refer to
Compliance and Disclosures Interpretation 102.10 which is available on our website at
http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm .

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the compa ny 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 provide a written statement from the compa ny
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect t o the filing; and

Mr. Russell Chenu
James Hardie Industries plc
January 9, 2013
Page 4

  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 Accountant , at (202) 551 -3733 or Nudrat Salik,
Staff Accountant , at (202) 551 -3692 if you have questions regarding these comments.

       Sincerely,

/s/ Rufus Decker

        Rufus Decker
       Accounting Branch Chief