[Barrett & McNagny Letterhead]
February 21, 2006
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Mail Stop 7010
Washington, D.C. 20549
Attention: Mr. Andrew P. Schoeffler, Staff Attorney
RE | Staff Comment No. 21 Regarding Exhibit 5.1 |
| Registration Statement on Form S-4 (File 333-131100) |
| SEC File No. 0-21719 |
Dear Mr. Schoeffler:
In connection with staff’s comment no. 21 in the February 10, 2006 Letter of Comment, the undersigned, as legal counsel to Steel Dynamics, Inc., the registrant, hereby confirms that he concurs with staff’s understanding that the reference to the “general corporation laws of the State of Indiana,” as employed in the legal opinion attached to the registration statement as Exhibit 5.1, includes the statutory provisions of Indiana law and all applicable provisions of the Indiana Constitution, as well as any reported judicial decisions interpreting these laws.
Very truly yours,
BARRETT & McNAGNY LLP
/s/ Robert S. Walters
Robert S. Walters