ÐÇ¿Õ´«Ã½

 

February 14, 2006
Via EDGAR
United States Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
     
Attention:
  H. Roger Schwall
Assistant Director
Division of Corporation Finance
       
Re:
  ÐÇ¿Õ´«Ã½ Inc Post-effective Amendment No. 1 on Form S-1, Registration
No. 333-131424
 
   
Ladies and Gentlemen:
     In accordance with Rule 477 promulgated under the Securities Act of 1933, ÐÇ¿Õ´«Ã½ Inc (the “Company”) hereby requests that the Company’s Registration Statement on Form S-1, File No. 333-131424 (the “Registration Statement”), and all exhibits thereto, be withdrawn effective immediately. The Company is withdrawing the Registration Statement, which has not been declared effective, because it was erroneously filed under the wrong registration statement number. The Company will separately file a post-effective amendment to its original Registration Statement on Form S-3, File No. 333-113252, to deregister the securities unsold thereunder.
     Should you have any further questions regarding this request for withdrawal, please do not hesitate to contact the undersigned at (216) 694-5446 or Jason Oblander at (216) 586-7461.
         
  Sincerely,


CLEVELAND-CLIFFS INC
 
 
  By:   /s/ George W. Hawk, Jr.    
    George W. Hawk, Jr.   
    Corporate Counsel and Secretary