Cliffs Natural Resources Inc.

200 Public Square

Cleveland, OH 44114 - 2315

February 26, 2009

Securities and Exchange Commission

100 F Street NE

Washington D.C. 20549-7010

Form 10-K Annual Report for Fiscal Year Ended December 31, 2008

Ladies and Gentlemen:

Pursuant to the requirements of the Securities and Exchange Act of 1934, we are transmitting herewith Form 10-K (including exhibits) for the year ended December 31, 2008.

The financial statements of Cliffs Natural Resources Inc. and Subsidiaries included in this report, for the year ended December 31, 2008, reflect no material changes from the preceding year in any accounting principles or practices, or in the method of applying any such principles or practices.