GSI [GENERAL STEEL] CORRESP: (Original Filing)

[November 1, 2011 VIA EDGAR 100 F Street, N.E. Re: General Steel Holdings, Inc. Ladies and Gentlemen: Set forth below are responses to the numbered comments. For your convenience, each response (each a “Response”, and collectively the “Responses”) follows the sequentially numbered comment copied from your letter of October 18, 2011. Form 10-K for the Fiscal Year Ended December 31,]

GSI [GENERAL STEEL] CORRESP: November 1, 2011 VIA EDGAR 100 F Street,

[November 1, 2011 VIA EDGAR 100 F Street, N.E. Re: General Steel Holdings, Inc. Ladies and Gentlemen: Set forth below are responses to the numbered comments. For your convenience, each response (each a “Response”, and collectively the “Responses”) follows the sequentially numbered comment copied from your letter of October 18, 2011. Form 10-K for the Fiscal Year Ended December 31,]

GSI [GENERAL STEEL] CORRESP: (Original Filing)

[VIA EDGAR 100 F Street, N.E. Re: General Steel Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed March 16, 2011 Form 10-Q for the Fiscal Quarter Ended March 31, 2011 Filed May 10, 2011 File No. 001-33717 Ladies and Gentlemen: Set forth below are responses to the numbered comments. For your convenience, each response (each]

GSI [GENERAL STEEL] CORRESP: VIA EDGAR 100 F Street, N.E. Re: General

[VIA EDGAR 100 F Street, N.E. Re: General Steel Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed March 16, 2011 Form 10-Q for the Fiscal Quarter Ended March 31, 2011 Filed May 10, 2011 File No. 001-33717 Ladies and Gentlemen: Set forth below are responses to the numbered comments. For your convenience, each response (each]

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