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May 12, 2022
Peter D. Fetzer
Partner
Foley & Larder LLP
777 East Wisconsin Avenue
Suite 3800
Milwaukee, WI 53202
Re:American Vanguard Corp.
Definitive Additional Soliciting Materials filed by Cruiser Capital Advisors,
LLC, et al.
Filed May 11, 2022
File No. 001-13795
Dear Mr. Fetzer:
            We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comments apply to your facts
and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Definitive Additional Soliciting Materials
An Insular & Long-Tenured Board Has Led To Poor Corporate Governance
1.We note your disclosure that "[t]he Board has only one 'Audit Committee Financial
Expert.' " With a view toward future revised disclosure, please tell us which of your
nominees would qualify as such an expert. If none of your nominees are such experts but
they are all elected while Mr. Erlich is not elected, the board would retain no such experts;
thus, revise your disclosure to clarify how the election of your nominees would affect the
board. See Item 407(d) of Regulation S-K.
2.Your disclosure that “AVD’s Board has a pattern of providing selective and misleading
disclosures in its press releases and SEC filings” suggests that the current board and the
company have not complied with the company's disclosure obligations. You must avoid

 FirstName LastNamePeter D. Fetzer
 Comapany NameFoley & Larder LLP
 May 12, 2022 Page 2
 FirstName LastName
Peter D. Fetzer
Foley & Larder LLP
May 12, 2022
Page 2
issuing statements that directly or indirectly impugn the character, integrity or personal
reputation or make charges of illegal, improper or immoral conduct without factual
foundation.  Please provide a factual foundation for your disclosure.  In this regard, note
that the factual foundation for such assertion must be reasonable.  Refer to Rule 14a-9.
            We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please direct any questions to Daniel Duchovny at 202-551-3619.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions