September 12, 2018

Kosei Shindo
President
NIPPON STEEL & SUMITOMO METAL CORP
6-1, Marunouchi 2-chome,
Chiyoda-ku, Tokyo, 100-8071, Japan

       Re: NIPPON STEEL & SUMITOMO METAL CORP
           Amendment No. 1 to Draft Registration Statement on Form F-4
           Submitted August 29, 2018
           CIK No. 0001140471

Dear Mr. Shindo:

      We have reviewed your amended draft registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-4

The Share Exchange
Valuation report of Nisshin Steel's Financial Advisor, page 32

1.     We note your response to comment 3. We continue to object to the
language on page B-4
       in the Valuation Report that states that shareholders are not entitled
to rely on the report
       and the disclosure on page 32 stating, "the Valuation Report was
prepared for the sole use
       of the board . . . ." Please revise accordingly.
 Kosei Shindo
NIPPON STEEL & SUMITOMO METAL CORP
September 12, 2018
Page 2


Appendix E, page E-1

2.       Please supplement your presentation of the unaudited consolidated
financial information
         prepared under Japanese GAAP for the three months ended June 30, 2018,
that was
         announced on August 2, 2018, to provide the information required by
Instruction 3 to Item
         8.A.5. of Form 20-F.
        You may contact Tracey Houser (Staff Accountant) at 202-551-3736 or
Terence O'Brien
(Accounting Branch Chief) at 202-551-3355 if you have questions regarding
comments on the
financial statements and related matters. Please contact Frank Pigott (Staff
Attorney) at 202-
551-3570 or Jay Ingram (Legal Branch Chief) at 202-551-3397 with any other
questions.



                                                             Sincerely,
FirstName LastNameKosei Shindo
                                          Division of Corporation Finance
Comapany NameNIPPON STEEL & SUMITOMO METAL CORP
                                          Office of Manufacturing and
September 12, 2018 Page 2                 Construction
FirstName LastName