VIA FACSIMILE AND U.S. MAIL January 20, 2006 Tony M. Shelby Executive Vice President of Finance and Chief Financial Officer LSB Industries, Inc. 16 South Pennsylvania Avenue Oklahoma City, Oklahoma 73107 RE: Form 10-K for the fiscal year ended December 31, 2004 File No. 1-07677 Dear Mr. Shelby: We have completed our review of your Form 10-K and related filings and have no further comments at this time. If you have any further questions regarding our review of your filings, please direct them to Ernest Greene, Staff Accountant, at (202) 551-3733 or in his absence, to Nudrat Salik, Staff Accountant, at (202) 551-3692. Sincerely, Rufus Decker Accounting Branch Chief ?? ?? ?? ?? UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE