SecProbe.io

CORRESP
1
filename1.htm

corresp

James Hardie Industries N.V.

Atrium 8th Floor

Strawinskylaan 3077

1077 ZX Amsterdam

The Netherlands

April 4, 2008

VIA EDGAR AND OVERNIGHT DELIVERY

Securities and Exchange Commission

Division of Corporation Finance

100 F Street

N.E., Stop 7010

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, 2007

Dear Mr. Decker,

Transmitted herewith is the response of James Hardie Industries N.V. (the “Company”) to the Staff’s
supplemental comment by letter dated March 26, 2008 (the “Comment Letter”) regarding the Company’s
Annual Report on Form 20-F for the fiscal year ended March 31, 2007 (the “20-F”). For ease of
reference, the Company has reproduced the comment set forth in the Comment Letter, as numbered,
before its 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 attributed to such terms in the 20-F. Courtesy copies of this letter are being delivered
to Brigitte Lippmann, Pamela Long, Ernest Greene and Jeanne Baker.

Securites and Exchange Commission

Page 2

Item 5 — Operating and Financial Review and Prospects — Page 47

Year ended March 31, 2007 Compared to Year Ended March 31, 2006 — Page 52

    1.

    We have read your response to comment two from our letter dated January 31, 2008. On page 5,
you indicate that net sales from Asia Pacific Fiber Cement increased 4% from $241.8 in fiscal
year 2006 to $251.7 million in fiscal year 2007 due to the increased sales volume and
favorable currency exchange rate differences, partially offset by a decreased average net sale
prices. In future filings, please quantify the impact of each business reason mentioned above
within your discussion of Asia Pacific fiber Cement Net Sales on a US dollar basis.

In future filings, the Company will quantify the impact of any material changes in foreign
exchange rates, sales volumes and the average net sales prices within its discussion of Asia
Pacific Fiber Cement Net Sales on a U.S. dollar basis.

***

Securities and Exchange Commission

Page 3

     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, with copies to Gary Epstein at Greenberg Traurig, P.A., 1221 Brickell Avenue, Miami,
Florida 33131, telecopy (305) 579-0717.

    Very truly yours,

    /s/ Russell Chenu

    Russell Chenu

    Chief Financial Officer

    cc:

    James Hardie Industries N.V

Louis Gries, Chief Executive Officer

Michael Hammes, Chairman of the Joint and Supervisory Boards

Brian Anderson, Chairman of the Audit Committee

Robert Bredenkamp, Corporate Financial Controller

    Securities and Exchange Commission

Jeanne Baker

Ernest Greene

Brigitte Lippmann

Pamela Long

    PricewaterhouseCoopers LLP

Shaun Matthews

    Greenberg Traurig P.A.

Gary Epstein

Barbara Oikle

Securities and Exchange Commission

Page 4

EXHIBIT A

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

         •

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

         •

    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.

    Date:  April 4, 2008
    /s/ Russell Chenu

    Russell Chenu

    Chief Financial Officer