[ Steelcase Letterhead ]
December 22, 2006
VIA EDGAR
Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
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Re: |
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Steelcase Inc. (CIK# 0001050825) Application for
Withdrawal
of Post-Effective Amendments Pursuant to Rule 477 of
the Securities Act of 1933, as Amended (the Securities Act) |
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act, Steelcase Inc., a Michigan corporation (the
Company), hereby applies for withdrawal of its (i) Post-Effective Amendment No. 1
(Post-Effective Amendment No. 1) to the Registration Statement on Form S-8 (File No. 333-46713)
(the ESPP Form S-8) and (ii) Post-Effective Amendment No. 2 (Post-Effective Amendment No. 2
and, together with Post-Effective Amendment No. 1, the Post-Effective Amendments) to the
Registration Statement on Form S-8 (File No. 333-84251) (the Retirement Plan Form S-8 and,
together with the ESPP Form S-8, the Forms S-8)), each as filed with the Securities and Exchange
Commission (the Commission) on December 15, 2006. The Post-Effective Amendments were incorrectly
transmitted to the Commission as POS AM filings.
The Company has terminated all offerings of its Class A Common Stock (the Common Stock) pursuant
to the Forms S-8 and no securities of the Company were sold in connection with the Post-Effective
Amendments. The Company will file on the date hereof corrective post-effective amendments under
filing type S-8 POS.
Please contact the undersigned at (616) 247-3201 with any questions concerning this application for
withdrawal. Thank you for your assistance in this matter.
Very truly yours,
/s/ Liesl A. Maloney
Liesl A. Maloney
Senior Corporate Counsel and Assistant Secretary