SEC Comment Letter for Ryerson Holding Corp (RYZ) (CIK 0001481582) (RYZ) — Jul 31, 2014
Ryerson Holding Corp (RYZ) (CIK 0001481582)
Date: July 31, 2014 · CIK: 0001481582 · Accession: 0000000000-14-038818
AI Filing Summary & Sentiment
Reasoning
Letter
July 31, 2014 Via E -mail Michael C. Arnold Chief Executive Officer and President Ryerson Holding Corporation 227 W. Monroe, 27th Floor Chica go, IL 60606
Re: Ryerson Holding Corporation Amendment No. 21 to Registration Statement on Form S -1 Filed July 24, 2014 File No. 333 -164484
Dear Mr. Arnold :
We have reviewed your response to our prior comment letter to you dated July 18, 201 4 and have the following additional comments .
Management’s Discussion and Analysis of Financial Condition, page 40
Contractual Obligations, page 53
1. We note your response to our prior comment 1 and the changes made to page 53 of the registration stateme nt in response to our prior comment. However, we are unable to determine where you have reflected the $25 million drawdown on the Credit Facility that will be made to fund the termination payment to Platinum in your pro forma table of contractual obligatio ns. Please advise or revise as appropriate.
Report of Independent Registered Public Accounting Firm, page F -2
2. We note your response to our prior comment 2, and reissue the comment. Prior to the planned effectiveness of the Company’s Form S -1 registrati on statement, please remove the restrictive legends included on the report and the consent of the independent registered public accounting firm.
Michael C. Arnold Ryerson Holding Corporation July 31, 2014 Page 2
You may contact Effie Simpson (202) 551 -3346 or Linda Cvrkel (202) 551 -3813 if you have questions regard ing comments on the financial statements and related matters. Please contact Ada D. Sarmento at (202) 551 -3798 or me at (202) 551 -3210 with any other questions.
Sincerely,
/s/ Susan Block
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July 31, 2014 Via E -mail Michael C. Arnold Chief Executive Officer and President Ryerson Holding Corporation 227 W. Monroe, 27th Floor Chica go, IL 60606 Re: Ryerson Holding Corporation Amendment No. 21 to Registration Statement on Form S -1 Filed July 24, 2014 File No. 333 -164484 Dear Mr. Arnold : We have reviewed your response to our prior comment letter to you dated July 18, 201 4 and have the following additional comments . Management’s Discussion and Analysis of Financial Condition, page 40 Contractual Obligations, page 53 1. We note your response to our prior comment 1 and the changes made to page 53 of the registration stateme nt in response to our prior comment. However, we are unable to determine where you have reflected the $25 million drawdown on the Credit Facility that will be made to fund the termination payment to Platinum in your pro forma table of contractual obligatio ns. Please advise or revise as appropriate. Report of Independent Registered Public Accounting Firm, page F -2 2. We note your response to our prior comment 2, and reissue the comment. Prior to the planned effectiveness of the Company’s Form S -1 registrati on statement, please remove the restrictive legends included on the report and the consent of the independent registered public accounting firm. Michael C. Arnold Ryerson Holding Corporation July 31, 2014 Page 2 You may contact Effie Simpson (202) 551 -3346 or Linda Cvrkel (202) 551 -3813 if you have questions regard ing comments on the financial statements and related matters. Please contact Ada D. Sarmento at (202) 551 -3798 or me at (202) 551 -3210 with any other questions. Sincerely, /s/ Susan Block Susan Block Attorney -Advisor cc: Via E -mail Christopher Greer, Esq .