October 20, 2005



Mr. Jay M. Gratz
Executive Vice President, Chief Financial Officer
Ryerson Tull, Inc.
2621 West 15th Place
Chicago, IL  60608


	Re:	Ryerson Tull, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2004
Filed March 22, 2005
		File No. 001-09117


Dear Mr. Gratz:

      We have reviewed your Form 10-K for the Fiscal Year Ended
December 31, 2004 and have the following comments.  We have
limited
our review of your filing to those issues we have addressed in our
comments.  Where indicated, we think you should revise your
document
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2004

Five Year Summary of Selected Financial Data and Operating Results
- -
Continuing Operations, page 19

1. We note your disclosure of "inventory - current value" and
"inventory turnover - current value basis" and the related
footnote
eight to the table presented on page 19.  Please amend your filing
to
include the disclosures required by Item 10 of Regulation S-K.

Note 4, Long-term Debt, page 50

$175 million 3.50% Convertible Senior Notes, page 52

2. Your disclosures indicate the convertible senior notes due 2024
have an "initial conversion price of approximately $21.37 per
share...subject to customary anti-dilution adjustments."  Please
describe how the conversion price is affected by the customary
anti-
dilution adjustments and identify the related agreements and
sections
within those agreements, which provide for these terms.

3. Tell us what consideration you have given to SFAS 133, EITF 00-
19
and other related accounting guidance and identify the conclusions
you reached in accounting for the conversion feature of your
convertible senior notes due 2024.

Note 18, Condensed Consolidating Financial Statements, page 70

4. Rule 3-10 of Regulation S-X allows for the presentation of
financial statements of guarantors of securities on a condensed
consolidating basis if certain criteria are met.  Please expand
your
disclosure to state, if true, that convertible notes due 2024 and
the
senior notes due 2011 are fully and unconditionally guaranteed by
Ryerson Tull Procurement Corporation.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Shannon Buskirk at (202) 551-3717 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3684 with any other
questions.

								Sincerely,



								April Sifford
								Branch Chief

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Mr. Jay M. Gratz
Ryerson Tull, Inc.
October 20, 2005
Page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010