Merrill Lynch, Pierce, Fenner & Smith
Incorporated
UBS Securities LLC
As Representatives of the several Underwriters
| c/o | Merrill Lynch, Pierce, Fenner & Smith |
| Incorporated |
One Bryant Park
New York, New York 10036
May 7, 2010
Via Facsimile and EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
| Re: | Ryerson Holding Corporation |
| Registration Statement on Form S-1 |
| (File No. 333-164484) |
Ladies and Gentlemen:
On May 4, 2010, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned, as Representatives of the several Underwriters requested that the effectiveness of the above-captioned Registration Statement on Form S-1 (as amended to date, the “Registration Statement”) be accelerated to Thursday, May 6, 2010 at 4:00 p.m., Eastern Daylight Time. The Representatives hereby withdraw their request for acceleration of effectiveness of the Registration Statement.
[SIGNATURE APPEARS ON THE FOLLOWING PAGE]
| Very truly yours, | ||
| Merrill Lynch, Pierce, Fenner & Smith | ||
| Incorporated | ||
| UBS Securities LLC | ||
| For themselves and on behalf of the several Underwriters | ||
MERRILL LYNCH, PIERCE, FENNER & SMITH | ||
| INCORPORATED | ||
| /s/ | Richard A. Diaz | |
| Name: | Richard A. Diaz | |
| Title: | Authorized Signatory | |
[Withdrawal of Acceleration Request]
| UBS SECURITIES LLC | ||
| /s/ | Jonathan Rose | |
Name: | Jonathan Rose | |
Title: | Executive Director | |
| /s/ | Matthew Albrecht | |
Name: | Matthew Albrecht | |
Title: | Associate Director | |
| cc: | Jonathan A. Schaffzin, Esq. |
| William J. Miller, Esq. |
[Withdrawal of Acceleration Request]