Flag Intermediate Holdings Corporation
Metals USA, Inc.
One Riverway, Suite 1100
Houston, Texas 77056
August 2, 2006
VIA EDGAR AND FACSIMILE (202) 772-9369
Securities and Exchange Commission
100 F Street, NE
Mail Stop 7010
Washington, D.C. 20549
Attn: Mr. H. Roger Schwall
| Re: | Flag Intermediate Holdings Corporation |
| Metals USA, Inc. |
| Form S-4 Initially Filed March 31, 2006 (the “Registration Statement”) |
| File No. 333-132918 |
Ladies and Gentlemen:
Flag Intermediate Holdings Corporation and Metals USA, Inc., on their own behalf and on behalf of each of the subsidiary guarantors listed on Appendix A to the acceleration request letter dated August 1, 2006 (collectively, the “Companies”), acknowledge that:
| • | Should 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 Companies from their full responsibility for the adequacy and accuracy in the Registration Statement; and |
| • | The Companies may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person and the federal securities laws of the United States. |
If you have any questions or comments on this matter, please feel free to call me at (713) 585-6408.
Very truly yours, |
/s/ Robert C. McPherson, III |
Robert C. McPherson, III Senior Vice President and Chief Financial Officer |
| cc: | C. Lourenço Gonçalves/Metals USA, Inc. |
| John A. Hageman/Metals USA, Inc. |
| J. Vincent Kendrick/Akin Gump Strauss Hauer & Feld LLP |
