SEC Comment Letter for Ryerson Holding Corp (RYZ) (CIK 0001481582) (RYZ) — Jun 17, 2016
Ryerson Holding Corp (RYZ) (CIK 0001481582)
Date: June 17, 2016 · CIK: 0001481582 · Accession: 0000000000-16-080965
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-211966
Letter
Mail Stop 3561 June 17, 2016 Erich S. Schnaufer Chief Financial Officer Ryerson Holding Corporation 227 W. Monroe St., 27th Floor Chicago, IL 60606
Re: Ryerson Holding Corporation Registration Statement on Form S-3 Filed June 10, 2016 File No. 333-211966
Dear Mr. Schnaufer :
This is to advise you that we have not reviewed and will not review your registration statement .
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 Act of 193 3 and all applicable Securities Act rules require. 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 the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and
the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under
Erich S. Schnaufer Ryerson Holding Corporation June 17, 2016 Page 2
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .
Please contact Julie Griffith at 202-551-3267 with any questions.
Sincerely,
/s/ Justin Dobbie
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Mail Stop 3561 June 17, 2016 Erich S. Schnaufer Chief Financial Officer Ryerson Holding Corporation 227 W. Monroe St., 27th Floor Chicago, IL 60606 Re: Ryerson Holding Corporation Registration Statement on Form S-3 Filed June 10, 2016 File No. 333-211966 Dear Mr. Schnaufer : This is to advise you that we have not reviewed and will not review your registration statement . 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 Act of 193 3 and all applicable Securities Act rules require. 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 the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under Erich S. Schnaufer Ryerson Holding Corporation June 17, 2016 Page 2 the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities . Please contact Julie Griffith at 202-551-3267 with any questions. Sincerely, /s/ Justin Dobbie Justin Dobbie Legal Branch Chief Office of Transportation and Leisure