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SEC Response Letter

 March 22, 2013

 Ms. Susan Block

 Attorney-Advisor

 United States Securities and Exchange Commission

 Division of Corporation Finance

100 F Street, N.E.

 Washington, D.C. 20549-7010

Re:
Ryerson Holding Corporation

Amendment No. 13 to the Registration Statement on Form S-1 (File No. 333-164484)

Dear Ms. Block:

 On
behalf of Ryerson Holding Corporation (the “Company”), set forth below are the Company’s responses to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
pertaining to the Company’s Amendment No. 13 to the Registration Statement on Form S-1 filed on April 13, 2012 (the “Registration Statement”) in respect of the initial public offering of shares of its common stock,
contained in your letter dated May 10, 2012 to Michael C. Arnold, Chief Executive Officer and President of the Company. On behalf of the Company, we hereby submit to the Commission Amendment No. 14 to the Registration Statement (the
“Amendment”) that contains changes made in response to the comments of the Staff. To facilitate your review, we have set forth each of your comments below with the Company’s corresponding response and have marked the enclosed
Amendment to reflect the changes. In addition, references to page numbers below pertain to the page numbers in the marked version of the Amendment submitted herewith. Defined terms used herein without definition have the meanings ascribed to them in
the Amendment.

 General

1.
Comment: Please revise to disclose the names of the lead underwriters in your next amendment.

Response: The Company will revise the Registration Statement in the next amendment thereto to disclose the names of the lead
underwriters where applicable.

 Prospectus Summary, page 1

 Our Company, page 1

2.
Comment: Refer to the second sentence. It is unclear to us what is meant by your belief that your presence in China “is the largest of any North American
metal service center.” Please revise for clarity. Similarly revise at page 4 under “China” and page 59 under “China.”

 Ms. Susan Block

 Attorney-Advisor

 United States Securities and Exchange Commission

Division of Corporation Finance

 March 22, 2013

  Page
 2

Response: The Company has revised the Registration Statement on pages 1 and 57 to comply with the Staff’s comment by deleting
the sentence relating to the Company’s belief that its presence in China is the largest of any North American metal service center.

3.
Comment: Please revise to disclose here that, because Platinum will control more than 50% of the voting power of the common stock after this offering, you
will be considered a controlled company for purposes of the NYSE listing requirements. In addition, please provide a brief summary of the effect such status could have on investors.

Response: The Company has revised the Registration Statement on page 2 to comply with the Staff’s comment.

4.
Comment: We note your disclosure on page 1 that you believe that you are one of the largest processors and distributors of metals in North America. Please
balance this statement by disclosing, if true, that the metal service center industry is highly fragmented and that the largest companies account for only a small percentage of total market share.

Response: The Company has revised the Registration Statement on pages 1 and 57 to comply with the Staff’s comment.

5.
Comment: It appears as though you may have closed one of your facilities in China. If this is true, please revise to disclose here so as to balance your
disclosure on page 1 regarding your “established and growing presence in China.”

 Response:
The Company acknowledges the Staff’s comment but respectfully submits that it continues to believe it has an established and growing presence in China. While the Company did close a service and processing center in Wuhan, China, it did so
because the Company did not believe the market in Wuhan was significant enough to the Company’s operations to warrant continued service in that region. The Company’s operations in Shanghai are servicing the region and believes that the
closing of the Wuhan facility did not have a material effect on the Company.

 Established and Growing Presence in International Markets,
page 4

6.
Comment: Please revise to clarify what is meant by you have “leveraged [y]our leadership.”

Response: The Company has revised the Registration Statement on pages 6 and 60 to comply with the Staff’s comment.

 - 2 -

 Ms. Susan Block

 Attorney-Advisor

 United States Securities and Exchange Commission

Division of Corporation Finance

 March 22, 2013

  Page
 3

 Diverse Customer
Base, and End Markets, page 4

7.
Comment: We note your disclosure that you continue to expand your customer base and have added over 4,000 net new customers since December 31, 2009.
Please also disclose the number of new customers you have added during the last fiscal year.

 Response:
The Company has revised the Registration Statement on pages 7 and 60 to delete the sentence relating to expansion of the Company’s customer base since December 31, 2009.

 Strong Relationships with Suppliers, page 5

8.
Comment: Please revise to state the last sentence in the second to last paragraph on page 5 as a belief.

Response: The Company has revised the Registration Statement on pages 7 and 61 to comply with the Staff’s comment.

Transformed Decentralized Operating Model, page 6

9.
Comment: Please provide the basis for you belief that you “have a favorable cost structure compared to many of [your] peers.”

 Response: The Company’s belief that Ryerson has a favorable cost structure compared to many of its
peers is based on a metric of operating expenses less depreciation and amortization expense as a percentage of sales. The Company’s analysis was based on a review of its public company peer group using publicly available data regarding six
of its publicly traded competitors. Ryerson’s expenses as a percentage of sales were the lowest or the second lowest of the peer group for the last eight consecutive quarters. On average, Ryerson’s expenses were lower by over 500
basis points compared to the peer group for the last eight quarters.

 Pursue Profitable Growth, page 6

10.
Comment: Please revise to balance your disclosure to clarify that there is no guarantee that you will be able to expand.

Response: The Company has revised the Registration Statement on pages 8 and 62 to comply with the Staff’s comment.

Our Strategy, page 6

11.
Comment: Please revise to balance the disclosure regarding accelerating your growth, given your recent net losses.

Response: The Company has revised the Registration Statement on pages 7 and 61 to comply with the Staff’s comment.

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 Ms. Susan Block

 Attorney-Advisor

 United States Securities and Exchange Commission

Division of Corporation Finance

 March 22, 2013

  Page
 4

 Expand Margins,
page 7

12.
Comment: Please revise to clarify what you mean on page 6 by “[s]ales to these businesses are typically transactional in nature” and “large
volume program buyers.”

 Response: The Company has revised the Registration Statement on pages 8
and 62 to comply with the Staff’s comment.

 Recent Developments, page 8

13.
Comment: We note the disclosure regarding the concurrent New Notes offering and that it is not being registered under the Securities Act of 1933. Please
provide us an analysis of the exemption from registration you are anticipating relying upon. In your response, please also provide your analysis as to why this registration statement should not be considered as being used as a general solicitation
for that private offering. Refer generally to Compliance and Disclosure Interpretations, Question 139.25 under Securities Act Sections.

 Response: The Company respectfully advises the Staff that the above referenced notes offering (the “Notes Offering”) was consummated in October 2012, and, as a result, will not
take place concurrently with the initial public offering. The Company respectfully submits that the Registration Statement should not be deemed to constitute an improper “general solicitation” in connection with the Notes Offering.

 In Securities Act Release No. 33-8828 (“Release 33-8828”) and in the Commission’s Compliance and
Disclosure Interpretation 139.25 (the “CDI”), the Commission confirmed its position that the filing of a registration statement does not, in itself, eliminate a company’s ability to engage in a concurrent private offering,
whether it is commenced before or after the filing of the registration statement. In Release 33-8828, the Commission noted that “the determination as to whether the filing of the registration statement should be considered to be a general
solicitation or general advertising that would affect the availability of a Section 4(2) exemption for such a concurrent unregistered offering should be based on a consideration of whether the investors in the private placement were solicited
by the registration statement or through some other means that would otherwise not foreclose the availability of the Section 4(2) exemption.” The Commission further stated that “companies and their counsel should analyze whether the
offering is exempt under Section 4(2) on its own, including whether securities were offered and sold to the private placement investors through the means of a general solicitation in the form of the registration statement…[I]f the
prospective private placement investor became interested in the concurrent private placement through some means other than the registration statement that did not involve a general solicitation and otherwise was consistent with Section 4(2),
such as through a substantive, pre-existing relationship with the company or direct

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 Ms. Susan Block

 Attorney-Advisor

 United States Securities and Exchange Commission

Division of Corporation Finance

 March 22, 2013

  Page
 5

contact by the company or its agents outside of the public offering effort, then the prior filing of the registration statement generally would not impact the potential availability of the
Section 4(2) exemption for that private placement and the private placement could be conducted while the registration statement for the public offering was on file with the Commission. Similarly, if the company is able to solicit interest in a
concurrent private placement by contacting prospective investors who (1) were not identified or contacted through the marketing of the public offering and (2) did not independently contact the issuer as a result of the general solicitation
by means of the registration statement, then the private placement could be conducted in accordance with Section 4(2) while the registration statement for a separate public offering was pending.” See Release 33-8828, pages 55-56.

 The Commission subsequently confirmed the interpretive guidance provided in Release 33-8828 in the CDI when it noted that
there can be a side-by-side private offering under Securities Act Section 4(2) or the Securities Act Rule 506 safe harbor with a registered public offering and that a registration statement would not serve as a general solicitation for a
private offering if investors became interested through some means other than the registration statement.

 The Company
respectfully advises the Staff that the Notes Offering was conducted (i) pursuant to a 144A offering process in which the notes offered in such Notes Offering were offered and sold only to “qualified institutional buyers” within the
meaning of Rule 144A promulgated under the Securities Act or (ii) in reliance on Regulation S, pursuant to which the notes offered in such Notes Offering were offered and sold only to non-U.S. persons outside the United States, and in each
case, the Company did not solicit interest in the private placement through the use of the Registration Statement. As noted in Release 33-8828, one of the key elements of the analysis of whether an offering may be exempt from the registration
requirements of the Securities Act is a determination that investors in a private placement are not solicited in a manner that uses the public offering process and the prospectus for such public offering as a general solicitation. The Company
solicited qualified institutional buyers and any non-U.S. persons under Regulation S only in a separate marketing process using a customary offering memorandum and solicitation process involving direct contact with the Company and its agents. In the
case of a 144A notes offering like the Notes Offering, the target investors of the notes are within a specific market for that type of security. In accordance with the guidance in Release 33-8828 and the CDI, potential investors in the Notes
Offering were not identified or contacted as a result of, or in connection with, the registration statement being on file, and the Company neither received nor accepted any offers from any purchasers that independently contacted the Company as a
result of reviewing the Registration Statement.

 - 5 -

 Ms. Susan Block

 Attorney-Advisor

 United States Securities and Exchange Commission

Division of Corporation Finance

 March 22, 2013

  Page
 6

 In
addition, pursuant to the proposed rules (the “Proposed Rules”) in Securities Act Release 33-9354 (“Release 33-9354”), which Proposed Rules have been approved by the Commission but not yet finalized, companies will
be allowed to offer securities being sold pursuant to Rule 144A using a general solicitation so long as the purchasers of the securities sold pursuant to Rule 144A are QIBs, or are reasonably believed to be QIBs by the seller of such securities or
any person acting on its behalf. Consequently, assuming adoption of the Proposed Rules, even if the Registration Statement was deemed to be a general solicitation, the notes that were sold in the Notes Offering pursuant to Rule 144A were sold to
QIBs and therefore, the actions of the Company were in accordance with the Proposed Rules in Release 33-9354.

 The Company
respectfully submits that, under these facts, consistent with the Commission’s guidance in Release 33-8828 and the CDI, the Registration Statement was not used as a general solicitation for the Notes Offering and the Company was permitted to
conduct the Notes Offering while the Registration Statement was pending or otherwise on file.

14.
Comment: Please revise to disclose here that you intend to enter into a registration rights agreement, pursuant to which you will agree to file with the SEC a
registration statement with respect to an offer to exchange each of the New Notes for a new issue of debt securities registered under the Securities Act and to consummate an exchange offer by a date to be agreed upon with the initial purchaser of
the New Notes.

 Response: The Company respectfully advises the Staff that the above referenced notes
offering was consummated in October 2012 and, as a result, will not take place concurrently with the initial public offering. In connection with the consummation of such notes offering, the Company entered into certain registration rights agreements
and has included disclosure with respect to such registration rights agreements on pages 48, 102, 104 and F-22 of the Registration Statement.

 Risk Factors, page 17

 The metal distribution business is very competitive and increased
competition could, page 18

15.
Comment: Given your recent net losses, please revise the risk factor subheading to remove the reference to “net income.”

 Response: The Company has revised the Registration Statement on page 18 to remove the reference to
“net income.”

 - 6 -

 Ms. Susan Block

 Attorney-Advisor

 United States Securities and Exchange Commission

Division of Corporation Finance

 March 22, 2013

  Page
 7

 We could incur
substantial costs related to environmental, health and safety laws, page 23

16.
Comment: Please revise to disclose here that, in October