November 29, 2006

Via U.S. Mail and Facsimile

Louis Gries
Chief Executive Officer
James Hardie Industries N.V.
Atrium, 8th Floor
Strawinskylann 3077
1077 ZX Amsterdam
The Netherlands

RE:		James Hardie Industries N.V.
		Form 20-F for the fiscal year ended March 31, 2006
		File No. 1-15240

Dear Mr. Gries:

      We have limited our review of your Form 20-F for the fiscal
year ended March 31, 2006, to disclosures relating to your
contacts
with countries that have been identified as state sponsors of
terrorism.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may raise additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


General -

1. We note that on page 34 of your 20-F you state that in addition
to
your principal markets you also sell fiber cement products in a
number of other countries, including Iran.  In light of the fact
that
Iran has been identified by the U.S. State Department as a state
sponsor of terrorism, and is subject to U.S. economic sanctions
and
export controls, please describe for us the extent and nature of
your
past, current, and anticipated contacts with Iran, whether through
distributors, subsidiaries or other direct or indirect
arrangements.
Include a discussion of direct and indirect contacts with the
Iranian
government and entities controlled by the Iranian government

2. Discuss the materiality to you of any contacts with Iran and
advise us of your view as to whether those contacts constitute a
material investment risk for your security holders.  In your
response, please address materiality in quantitative terms,
including
the dollar amount of any associated revenues, assets or
liabilities.
Please also address materiality in terms or qualitative factors
that
a reasonable investor would deem important in making an investment
decision, including the potential impact of corporate activities
upon
a company`s reputation and share value.

We note, for example, that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism.  The Pennsylvania legislature has adopted a resolution
directing its Legislative Budget and Finance Committee to report
annually to the General Assembly regarding state funds invested in
companies that have ties to terrorist-sponsoring countries.  The
Missouri Investment Trust has established an equity fund for the
investment of certain state-held monies that screens out stocks of
companies that do business with U.S.-designated state sponsors of
terrorism.  Your materiality analysis should address the potential
impact of the investor sentiment evidenced by such actions
directed
toward companies that have business contacts with Iran.

Your qualitative materiality analysis also should address whether,
and the extent to which, the Iranian government or entities
controlled by the Iranian government receive cash or act as
intermediaries in connection with your operations.





Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.
								Sincerely,


								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Pamela Long
		Rufus Decker
		Division of Corporation Finance
Louis Gries
James Hardie Industries N.V.
November 29, 2006
Page 1









UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE