[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,]