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    James Hardie Industries N.V.

Atrium 8th Floor

Strawinskylaan 3077

1077 ZX Amsterdam

The Netherlands

December 22, 2009

VIA EDGAR AND OVERNIGHT DELIVERY

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E., Stop 4631

Washington D.C. 20549

Attention: Mr. Rufus Decker

    Re:

    James Hardie Industries N.V.

File No. 1-15240

Form 20-F for the fiscal year ended March 31, 2009

Dear Mr. Decker:

     The Staff provided supplemental comments, by letter dated December 16, 2009 (the “Comment
Letter”), regarding the Company’s Annual Report on Form 20-F for the fiscal year ended March 31,
2009 (the “20-F”).

     For ease of reference, the Company has reproduced the comment set forth in the Comment Letter,
as numbered, in bold type before the response below. Unless otherwise noted, page numbers included
herein are page references to the Company’s 20-F, and capitalized terms used but not defined herein
have the same meanings ascribed to such terms in the 20-F. Courtesy copies of this letter are being
delivered to Jay Ingram, Jeanne Baker and Jeffrey Gordon.

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 the use of these assets is restricted to the settlement of asbestos claims and
payment 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 March 31, 2009, you present current restricted cash and cash
equivalents related to asbestos in the amount of $45.4 million and current restricted
short-term investments related to asbestos in the amount of $52.9 million, while your current
asbestos liability is $78.2

Mr. Rufus Decker

Securities and Exchange Commission

Page 2

million. Given your restricted current assets related to asbestos are greater than your
current asbestos liability, please 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 current and non-current
amounts in your consolidated balance sheets based on the current and non-current
classification of your estimated claims liability.

We note the Staff’s comment asking what the Company considered in presenting certain
amounts of restricted assets related to asbestos as non-current assets and the Company’s
intentions with respect to recording cash and cash equivalents between current and
non-current amounts in our balance sheets based on the current and non-current
classification of our estimated claims liability.

 We respectfully submit that it is
the Company’s intention to record cash and cash equivalents between current and non-current
amounts in our balance sheets based on the current and non-current classification of our
estimated insurance claims liability with respect to certain letters
of credit (with insurance companies) under which it is
contractually obligated.

However, the Company’s restricted assets related to asbestos are not
encumbered by such contractual obligations and can be and are used by the AICF without restriction
to settle AICF liabilities and operating expenses and are not for the sole purpose of
settling the AICF’s current asbestos liability. Accordingly, we believe the previously
proposed presentation and approach to recording assets between current and non-current
assets is appropriate.

***

     You may call the undersigned with any questions or comments you may have regarding this letter
at +31 20 301 6794. In addition, please send all written correspondence directly to the undersigned
at facsimile +31 20 404 2544, with copies to James J. Moloney of Gibson, Dunn & Crutcher LLP, 3161
Michelson Drive, 12th Floor, Irvine, California 92612, facsimile (949) 475-4756.

    Very truly yours,

    /s/ Russell Chenu

    Russell Chenu

    Chief Financial Officer

Mr. Rufus Decker

Securities and Exchange Commission

Page 3

    cc:

    James Hardie Industries N.V.

    Louis Gries, Chief Executive Officer

    Robert Cox, General Counsel

    Michael Volk, Corporate Financial Controller

    Michael Hammes, Chairman of the Joint and Supervisory Boards

    Brian Anderson, Chairman of the Audit Committee

    Securities and Exchange Commission

    Jay Ingram

    Jeanne Baker

    Jeffrey Gordon

    Ernst & Young

    John Faulkner

    PricewaterhouseCoopers LLP

    Shaun Matthews

    Gibson, Dunn & Crutcher LLP

    Mark W. Shurtleff

    James J. Moloney

EXHIBIT A

I, Russell Chenu, Chief Financial Officer of James Hardie Industries N.V. (the “Company”), do
hereby acknowledge that:

    1.

    The Company is responsible for the adequacy and accuracy of the disclosure in its
filings;

    2.

    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

    3.

    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.

    Date: December 22, 2009
    /s/ Russell Chenu

    Russell Chenu

    Chief Financial Officer