March 30, 2007

Via U.S. Mail and Facsimile

Ku-Taek Lee
Chief Executive Officer
POSCO
892 Daechi-4-dong
Gangnam-gu
Seoul, Korea


RE:		POSCO
		Form 20-F for the fiscal year ended December 31, 2005
		File No. 1-13368

Dear Mr. Lee:

      We have limited our review of your Form 20-F for the fiscal
year ended December 31, 2005, 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 news reports that your subsidiary POSCO Engineering &
Construction entered into contracts to build a mini mill in Iran
and
to build two gas-fired power plants in Iran.  We also note that on
your website you have press releases stating that your engineering
and construction subsidiary won a contract from the state owned
National Iranian Steel Co. for the construction of a coking plant
for
processing coal.
Iran has been identified as a state sponsor of terrorism by the
U.S.
State Department and is subject to U.S. economic sanctions and
export
controls.  Please describe your current, past and anticipated
operations in and contacts with Iran, whether directly or through
subsidiaries or other indirect arrangements, and discuss their
materiality to you in light of Iran`s status as a state sponsor of
terrorism.  Please also discuss whether the contacts and
operations
constitute a material investment risk to your security holders.
2. Your materiality analysis should address materiality in
quantitative terms, including the approximate dollar amount of
revenues, assets and liabilities associated with Iran.  Please
also
address materiality in terms of 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.
In this regard, we note 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 operate in Iran.
3. Advise us whether (i) any of the products, including component
parts, or services you have provided into Iran have military uses;
and (2) whether, to the best of your knowledge, understanding or
belief, they have been put to military use by the Iranian
government
and, if so, the uses to which they have been put.
4. Please address for us the applicability to your Iran-related
activities, including any direct or indirect payments to the
Iranian
government, of Section 5(b) of the Iran Sanction Act of 1996, as
modified by the Iran Freedom Support Act on September 30, 2006.
5. We note that you have posted on your website a press release
stating that your corrugated steel plates were to be used in the
construction of a road linking South and North Korea.  Please
advise
us whether this endeavor has been completed, and whether it
involved
contacts with North Korea.  If so, please describe those contacts.
Advise us whether you have had, have or anticipate having other
North
Korea-related operations.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please submit 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
		Division of Corporation Finance