B. Andrew Rose

Chief Financial Officer

April 3, 2009

Mr. John Cash

Accounting Branch Chief

Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549-7010

Dear Mr. Cash:

This letter is in response to the comment of the Securities and Exchange Commission (the “Commission “) provided in your letter dated March 24, 2009, as a follow-up to the response from Worthington Industries, Inc. (the “Company,” “we,” or “our”). In responding to this comment, we acknowledge that:

Mr. John Cash

April 3, 2009

Page 2

The following is your comment followed by our response:

Worthington Industries, Inc. Schedule 14A

Compensation Discussion and Analysis, page 22

Response:

Item 402(b)(2)(xiv) of Regulation S-K provides that a Registrant should discuss:

(xiv) Whether the registrant engaged in any benchmarking of total compensation, or any material element of compensation, identifying the benchmark and, if applicable, its components (including component companies); and

We believe the following material from pages 23 and 24 of our 2008 Proxy Statement addressed most of the information contemplated by this item. It provides a description of the comparator group and states that comparator group information is reviewed with respect to “base salaries, bonuses, and long-term incentive programs.”

The [Compensation] Committee annually reviews certain market compensation information with the assistance of an independent compensation consultant, Towers Perrin, who is directly engaged by the Committee to prepare the information. This information includes information regarding compensation paid to officers with similar responsibilities by a broad-based group of more than 120 manufacturing companies with revenues between $1 billion and $10 billion (the “comparator group”). For comparison purposes, due to variance in size of the companies in the comparator group, regression analysis, which is an objective analytical tool used to determine the relationship between data, is used to adjust data. The Compensation Committee believes that using this broad-based comparator group minimizes the effects of changes to the group due to changes in data-base participation or mergers/acquisitions, lessens the impact a single entity can have on the overall data, provides more consistent results and better reflects the market in which the Company competes for executive talent.

During its review process, the Compensation Committee meets directly with the compensation consultant to review and evaluate comparator group information with respect to base salaries, bonuses and long-term incentive programs. The Company and the Compensation Committee are committed to reviewing compensation for market competitiveness, and to employing incentive compensation vehicles and practices that continue to drive Company performance and that are aligned with shareholder

Mr. John Cash

April 3, 2009

Page 3

interests. The Compensation Committee reviews the information provided by the compensation consultant as an important factor in determining the appropriate levels and mix of executive compensation.

The following provides additional information on the comparator group and its component companies.

The comparator group comprises all manufacturing companies maintained in the executive compensation database of our compensation consultant at the time the study is conducted with revenues between $1 billion and $10 billion. Changes in that group occur as companies begin or cease participation in the database, due to the sale, merger or acquisition of companies included, due to an increase or decrease in revenues, or for other reasons.

Exhibit A sets forth the entities in the comparator group at the time of the Towers-Perrin study.

We would intend to include additional information similar to the above in future filings as it remains applicable.

We believe the above is responsive to your comments. Should you need further information, please contact Dale Brinkman, General Counsel at (614) 438-3001.

EXHIBIT A

Manufacturing Industry Companies between $1 - $10B

EXHIBIT A