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November 17, 2021
James Claussen
Executive Vice President and Chief Financial Officer
Ryerson Holding Corporation
227 W. Monroe St.
27th Floor
Chicago, IL 60606
Re:Ryerson Holding Corporation
Form 10-K for the Year Ended December 31, 0220
Filed February 24, 2021
Form 8-K
Filed November 3, 2021
File No. 001-34735
Dear Mr. Claussen:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2020
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Operating activities, page 42
1.Net cash of operating activities materially varied between the annual periods presented as
well as between the interim periods in the Form 10-Q for the period ended September 30,
2021.  Your disclosure appears to emphasize how net cash of operating activities was
derived for each period, and refers to noncash items that do not impact cash.  Pursuant to
Item 303 of Regulation S-K, your discussion should be an analysis of material changes
that affected operating cash between comparable periods.  Refer to the introductory
paragraph of section IV.B and paragraph B.1 of Release No. 33-8350 for guidance.

 FirstName LastNameJames  Claussen
 Comapany NameRyerson Holding Corporation
 November 17, 2021 Page 2
 FirstName LastName
James  Claussen
Ryerson Holding Corporation
November 17, 2021
Page 2
Please revise your disclosure as appropriate.
Form 8-K Furnished November 3, 2021
Exhibit 99.1
Q3 2021 Highlights
2.In the third bullet you state “Achieved record Adjusted EBITDA, excluding LIFO … . ”
Please state in the bullets with equal or greater prominence the comparable GAAP
measure.  Refer to Item 10(e)(1)(i)(A) of Regulation S-K.
Exhibit 99.2
3.Please present with equal or greater prominence the comparable GAAP measure to the
non-GAAP measures wherever presented herein.  For example (but not necessarily
exclusive), “Adj. EBITDA, excl. LIFO” under “Fourth Quarter Guidance,” “Q3 2021
Selected Financial and Operating Metrics Update,” “Q3 2021 vs. Q2 2021 Financial
Performance” and "Quarterly Financial Highlights,” as well as several measures under
“Q3 2021 Key Financial Metrics.”
4.It appears your presentation of “Operating Cash Flow per Share” measures is prohibited
pursuant to Question 102.05 of the Staff’s Compliance and Disclosure Interpretations on
Non-GAAP Financial Measures and the guidance cited therein.  Please revise as
appropriate.
Financial Highlights
5.Please present with equal or greater prominence the comparable GAAP measure as a
percentage of revenue to “Adj. EBITA, excl. LIFO” as a percentage of revenue presented
in the table.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Robert Shapiro at 202-551-3273 or Doug Jones at 202-551-3309 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Molly Kannan, Controller and CAO