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SEC Company Response from Ryerson Holding Corp (RYZ) (CIK 0001481582) (RYZ) — Aug 1, 2014

Ryerson Holding Corp (RYZ) (CIK 0001481582)
Date: Aug. 1, 2014 · CIK: 0001481582 · Accession: 0001193125-14-291319

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-164484

Date
August 1, 2014
Author
By
Form
CORRESP
Company
Ryerson Holding Corp (RYZ) (CIK 0001481582)

Letter

Acceleration Request

RYERSON HOLDING CORPORATION

227 W. Monroe, 27th Floor

Chicago, IL 60606

August 1, 2014

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Ryerson Holding Corporation

Registration Statement on Form S-1

File No. 333-164484

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Ryerson Holding Corporation (the “Company”) hereby respectfully requests that the effectiveness of the above-captioned Registration Statement on Form S-1 (as amended to date, the “Registration Statement”) be accelerated to August 6, 2014 at 4:00 p.m., Eastern Daylight Time, or as soon as practicable thereafter. Under separate cover, you will receive today a letter from the managing underwriters of the proposed offering joining in the Company’s request for acceleration of the effectiveness of the Registration Statement.

The Company hereby acknowledges that:

•

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the accuracy and adequacy of the disclosure in the Registration Statement; 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 confirm that the Registration Statement has been declared effective by telephoning Cristopher Greer, Esq. of Willkie Farr & Gallagher LLP at (212) 728-8214. Comments with respect to this request or the Registration Statement may be directed to Mr. Greer by telephone or facsimile at (212) 728-9214.

The cooperation of the staff in meeting the timetable described above is very much appreciated.

Sincerely,
RYERSON HOLDING CORPORATION

Show Raw Text
CORRESP
1
filename1.htm

Acceleration Request

 RYERSON HOLDING CORPORATION

227 W. Monroe, 27th Floor

 Chicago, IL 60606

 August 1, 2014

 VIA EDGAR

 United States Securities and Exchange Commission

Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

 Re: Ryerson Holding Corporation

 Registration Statement on Form S-1

File No. 333-164484

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities Act
of 1933, as amended, Ryerson Holding Corporation (the “Company”) hereby respectfully requests that the effectiveness of the above-captioned Registration Statement on Form S-1 (as amended to date, the “Registration
Statement”) be accelerated to August 6, 2014 at 4:00 p.m., Eastern Daylight Time, or as soon as practicable thereafter. Under separate cover, you will receive today a letter from the managing underwriters of the proposed offering joining in
the Company’s request for acceleration of the effectiveness of the Registration Statement.

 The Company hereby
acknowledges that:

•

 should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the
Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

•

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve
the Company from its full responsibility for the accuracy and adequacy of the disclosure in the Registration Statement; 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 confirm that the Registration Statement has
been declared effective by telephoning Cristopher Greer, Esq. of Willkie Farr & Gallagher LLP at (212) 728-8214. Comments with respect to this request or the Registration Statement may be directed to Mr. Greer by telephone or facsimile at (212)
728-9214.

 The cooperation of the staff in meeting the timetable described above is very much appreciated.

 Sincerely,

RYERSON HOLDING CORPORATION

By:

/s/ Edward J. Lehner

Name:

Edward J. Lehner

Title:

Chief Financial Officer

cc:
Cristopher Greer, Esq.

 Jared
Nicholson, Esq.

 [Signature Page to Acceleration Request]