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March 25, 2020
Correspondence Filing Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Re:
ÐÇ¿Õ´«Ã½ Inc.
Registration Statement on Form S-4 (Registration No. 333-237325)
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 (Registration No. 333-237325) of Cliffs and the subsidiary co-registrants named therein be declared effective at 9:00 a.m. on Friday, March 27, 2020, 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.






Very truly yours,
CLEVELAND-CLIFFS INC.
 
By:
/s/ James D. Graham
 
Name:
James D. Graham
 
Title:
Executive Vice President, Chief Legal Officer & Secretary

cc:
Michael J. Solecki, Esq. (Jones Day)



[Signature Page to Request for Acceleration of Effectiveness]