March 26, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Re: ÐÇ¿Õ´«Ã½ Inc.
Registration Statement on Form S-4 (Registration No. 333-223027)
Ladies and Gentlemen:
On behalf of ÐÇ¿Õ´«Ã½ Inc. (“Cliffs”), the undersigned hereby requests, pursuant to Rule 461(a) promulgated under the Securities Act of 1933, that the Registration Statement on Form S-4 (File No. 333-223027) of Cliffs and the subsidiary co-registrants named therein be declared effective at 9:00 a.m. on Thursday, March 29, 2018, or as soon thereafter as practicable. Cliffs respectfully requests that you notify Michael J. Solecki of such effectiveness by a telephone call to (216) 586-7103.
Please contact Michael J. Solecki of Jones Day at (216) 586-7103 if you have any questions concerning this matter. Thank you for your continued attention to this matter.
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Very truly yours, |
CLEVELAND-CLIFFS INC. |
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By: | /s/ Timothy K. Flanagan |
| Name: | Timothy K. Flanagan |
| Title: | Executive Vice President, Chief Financial Officer |
cc: Michael J. Solecki, Esq.
