SEC Comment Letter for DANA INC (DAN) (CIK 0000026780) (DAN) — Jan 10, 2012

DANA INC (DAN) (CIK 0000026780)
Date: Jan. 10, 2012 · CIK: 0000026780 · Accession: 0000000000-12-001521

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File numbers found in text: 001-01063

Date

January 10, 2012

Author

Linda Cvrkel Branch Chief

Form

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Company

DANA INC (DAN) (CIK 0000026780)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE January 10, 2012 Via E-mail Mr. James A. Yost Chief Financial Officer Dana Holding Corporation 3939 Technology Drive Maumee, Ohio 43537

Re: Dana Holding Corporation Form 10-K for the year ended December 31, 2010 Filed February 24, 2011 File No. 001-01063

Dear Mr. Yost: We have completed our review of your f ilings. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely, /s/ Linda Cvrkel
Linda Cvrkel Branch Chief

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

        January 10, 2012  Via E-mail

Mr. James A. Yost Chief Financial Officer Dana Holding Corporation 3939 Technology Drive Maumee, Ohio 43537

Re: Dana Holding Corporation
 Form 10-K for the year ended December 31, 2010
Filed February 24, 2011
 File No. 001-01063

Dear Mr. Yost:
 We have completed our review of your f ilings.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or the filings and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,  /s/ Linda Cvrkel

Linda Cvrkel Branch Chief

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