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SEC Company Response from Ryerson Holding (RYZ) — Jan 12, 2026

Ryerson Holding Corp
Date: Jan. 12, 2026 · CIK: 0001481582 · Accession: 0001193125-26-010396

Offering / Registration Process

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Reasoning

File numbers found in text: 333-291983

Date
January 12, 2026
Author
/s/ Mark S. Silver
Form
CORRESP
Company
Ryerson Holding Corp

Letter

RYERSON HOLDING CORPORATION 227 West Monroe Street, 27 th Floor Chicago, Illinois 60606 January 12, 2026 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, DC 20549 Re: Ryerson Holding Corporation (CIK No. 0001481582) (the “Registrant”) Registration Statement on Form S-4 Filed December 5, 2025, as amended File No. 333-291983 Dear Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Ryerson Holding Corporation hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. Eastern Time on Wednesday, January 14, 2026, or as soon as thereafter practicable.

Very truly yours,
/s/ Mark S. Silver

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CORRESP
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 filename1.htm

 CORRESP

 RYERSON HOLDING CORPORATION
 227 West Monroe Street, 27 th Floor
 Chicago, Illinois 60606
 January 12, 2026 VIA EDGAR
 U.S. Securities and Exchange Commission Division of
Corporation Finance Office of Real Estate & Construction
 100 F Street, N.E. Washington, DC 20549
 Re: Ryerson Holding Corporation (CIK No. 0001481582) (the “Registrant”)
 Registration Statement on Form S-4
 Filed December 5, 2025, as amended File No. 333-291983 Dear Ladies and Gentlemen:
 Pursuant to Rule 461 under the Securities Act of 1933, as amended, Ryerson Holding Corporation hereby requests acceleration of effectiveness of
the above referenced Registration Statement so that it will become effective at 4:00 p.m. Eastern Time on Wednesday, January 14, 2026, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Mark S. Silver

 Mark S. Silver

 Executive Vice President, General Counsel and Chief Human Resources Officer

 cc:
 Brian Hamilton, Willkie Farr & Gallagher LLP
 Thomas Sharkey, Willkie Farr & Gallagher LLP