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SEC Company Response from Ryerson Holding Corp (RYZ) (CIK 0001481582) (RYZ) — Aug 6, 2014

Ryerson Holding Corp (RYZ) (CIK 0001481582)
Date: Aug. 6, 2014 · CIK: 0001481582 · Accession: 0001193125-14-298576

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-164484

Date
August 6, 2014
Author
Managing Director
Form
CORRESP
Company
Ryerson Holding Corp (RYZ) (CIK 0001481582)

Letter

Acceleration Request

Merrill Lynch, Pierce, Fenner & Smith Incorporated

Deutsche Bank Securities Inc.

BMO Capital Markets Corp.

As representatives of the several Underwriters

c/o Merrill Lynch, Pierce, Fenner & Smith Incorporated

One Bryant Park

New York, New York

VIA EDGAR

August 6, 2014

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Ryerson Holding Corporation (the “Company”)

Registration Statement on Form S-1 (File No. 333-164484)

Ladies and Gentlemen:

As representatives of the several underwriters of the Company’s proposed public offering of common stock, we hereby join the Company’s request that the effective date of the above-referenced Registration Statement be accelerated so that the above-referenced Registration Statement will be declared effective at 4:00 p.m. EST on August 7, 2014, or as soon thereafter as is practicable.

Pursuant to Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated July 24, 2014, through the date hereof:

Preliminary Prospectus dated July 24, 2014:

1,684 copies to prospective underwriters, institutional investors, dealers and others

The undersigned advise that they have complied and will continue to comply, and that they have been informed by the participating underwriters and dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Remainder of Page Intentionally Left Blank]

Very truly yours,
MERRILL LYNCH, PIERCE, FENNER & SMITH

Show Raw Text
CORRESP
1
filename1.htm

Acceleration Request

 Merrill Lynch, Pierce, Fenner & Smith Incorporated

Deutsche Bank Securities Inc.

BMO Capital Markets Corp.

As representatives of the several Underwriters

c/o Merrill Lynch, Pierce, Fenner & Smith Incorporated

One Bryant Park

 New York, New York
10036

 VIA EDGAR

 August 6, 2014

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
Ryerson Holding Corporation (the “Company”)

 Registration Statement on Form S-1 (File
No. 333-164484)

 Ladies and Gentlemen:

As representatives of the several underwriters of the Company’s proposed public offering of common stock, we hereby join the
Company’s request that the effective date of the above-referenced Registration Statement be accelerated so that the above-referenced Registration Statement will be declared effective at 4:00 p.m. EST on August 7, 2014, or as soon
thereafter as is practicable.

 Pursuant to Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under
the Securities Act of 1933, as amended, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated July 24, 2014, through the date hereof:

Preliminary Prospectus dated July 24, 2014:

1,684 copies to prospective underwriters, institutional investors, dealers and others

The undersigned advise that they have complied and will continue to comply, and that they have been informed by the participating underwriters
and dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Remainder of Page Intentionally Left Blank]

Very truly yours,

MERRILL LYNCH, PIERCE, FENNER & SMITH

 INCORPORATED

By:

 /s/ Michele A.H. Allong

Name:

Michele A.H. Allong

Title:

Authorized Signatory

 For itself and as a Representative of the several Underwriters

[Signature Page to Acceleration Request by Underwriters]

 DEUTSCHE BANK SECURITIES INC.

By:

 /s/ Francis Windels

Name:

Francis Windels

Title:

Managing Director

By:

 /s/ Benjamin Marsh

Name:

Benjamin Marsh

Title:

Director

 For itself and as a Representative of the several Underwriters

[Signature Page to Acceleration Request by Underwriters]

BMO CAPITAL MARKETS CORP.

By:

 /s/ Lori A. Begley

Name:

Lori A. Begley

Title:

Managing Director

 For itself and as a Representative of the several Underwriters

[Signature Page to Acceleration Request by Underwriters]