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  King & Spalding LLP

1100 Louisiana Street

Suite 4100

Houston, TX 77002-5213

Tel: +1 713 751 3200

Fax: +1 713 751 3290

www.kslaw.com

September
6, 2024

VIA EDGAR

    Securities and Exchange Commission

    Division of Corporation Finance

    100 F Street, N.E.

    Washington, D.C. 20549

    Attention:  Bradley Ecker

    Jennifer Angelini

    Charles Eastman

    Martin James

 Re: Glatfelter Corporation

Registration Statement on Form S-4

Filed on August 23, 2024

File No. 333-281733

Dear Mr. Ecker:

On behalf of Glatfelter Corporation,
a Pennsylvania corporation (the “Company”), we hereby respond to the comment letter from the staff of the Division
of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated September 3, 2024, regarding the Company’s Registration Statement on Form S-4 (File No. 333-281733) filed on August 23, 2024
(the “Registration Statement”).

Please note for your convenience,
we have included the Staff’s comments in boldface type and provided the Company’s response to the comment immediately thereafter.
Capitalized terms used but not defined in this letter have the meanings ascribed to them in the Registration Statement.

We have also attached as Exhibit
A to this letter a proposed marked copy of the tax opinion to be filed as Exhibit 8.1 to the Amendment No. 1 to the Registration
Statement (“Amendment No. 1”), a proposed marked copy of the section entitled “Material U.S. Federal Income Tax
Consequences”, in each case reflecting revisions responsive to the Staff’s comments, as well as a copy of the preliminary
form of proxy card. Subject to any additional comments from the Staff, the Company intends to incorporate these and any other revisions
responsive to the Staff’s comments in, include the preliminary form of proxy card as an appendix to, and file the revised tax opinion
as Exhibit 8.1 to the Registration Statement with the Amendment No. 1 on the same day (or the day thereafter, if need be) that the Staff
confirms no further comments and, following such filing, request effectiveness of the Registration Statement 48 hours thereafter, with
a goal of going effective next week, if possible, as previously discussed.

Securities and Exchange Commission

 September 6, 2024

Page 2

Form S-4 filed August 23, 2024

Material U.S. Federal Income Tax Consequences,
page 215

 1. We note you have included a short-form tax opinion as Exhibit 8.1 to the registration statement. Please
revise this section to state clearly that the disclosure is the opinion of named counsel, and to ensure that the disclosure clearly identifies
and articulates the opinion being rendered with respect to each material tax consequence being opined upon. Refer to Sections III.B and
III.C of Staff Legal Bulletin 19 for guidance. Without limitation, address the following:

 · Revise disclosures on pages 216 and 217 that appear to inappropriately condition the opinion: "Provided
Berry receives the IRS Ruling and the Tax Opinion, the Spinco Distribution, so qualifies as a tax-free distribution, and the IRS Ruling
and Tax Opinion continue to be valid, and in full force and effect" and "Provided that Berry receives the Tax Opinion, the Merger
so qualifies as a 'reorganization,' and the Tax Opinion continues to be valid, and in full force and effect."

 · Revise disclosure on page 218 that assumes the reverse stock split will not be integrated, and effectively
describes the related tax consequences hypothetically, to fully discuss the expected tax treatment and consequences. If this opinion is
subject to uncertainty, counsel may issue a "should" or "more likely than not" opinion, disclose why it cannot give
a "will" opinion, describe the degree of uncertainty in the opinion, and provide relevant risk factor disclosure.

In response to the Staff’s comment,
the disclosures in the section entitled “Material U.S. Federal Income Tax Consequences” have been revised and are attached
hereto in Exhibit A.

Exhibits

 2. Please revise the tax opinion filed as Exhibit 8.1 to address the following:

 · The assumptions in paragraphs (b)-(d) appear to inappropriately refer to the registration statement
in contractual terms. Counsel may assume that the registration statement has been declared effective pursuant to the Securities Act. Refer
to Section II.B.3.a of Staff Legal Bulletin 19.

 · The assumptions in paragraphs (c) and (d) appear overly broad. Refer to Sections II.B.3.a and III.C.3
of Staff Legal Bulletin 19 for guidance.

 · The statement, "no opinion should be inferred as to the tax consequences, whether federal, state,
local or foreign, of any transactions related to the Statements," appears inconsistent with your opinion "as to the material
United States federal income tax consequences of the Spinco Distribution . . . and the Merger."

In response to the Staff’s comment,
Bryan Cave Leighton Paisner LLP has revised the tax opinion filed as Exhibit 8.1, and a marked copy is attached hereto in Exhibit A.

Securities and Exchange Commission

 September 6, 2024

 Page 3

General

 3. Please include a form of proxy card marked as “preliminary” in your next amendment. Note
that this should be filed as an appendix rather than an as exhibit. Refer to Note to paragraph (a)(3) of Exchange Act Rule 14a-4.

In response to the Staff’s comment,
the Company will include a preliminary form of proxy card as an appendix to the Amendment No. 1, as provided in Exhibit A attached hereto.

* * * * * * * * * * * * *

If you have any questions
or require any additional information regarding the foregoing, please contact me at (713) 276-7382.

    Sincerely,

    /s/ Jonathan B. Newton

    Jonathan B. Newton

 cc: Jill L. Urey, Glatfelter Corporation

Robert J. Leclerc, King &
Spalding LLP

Trevor G. Pinkerton, King
 & Spalding LLP

Jason K. Greene, Berry Global
Group, Inc.

Eliot Robinson, Bryan Cave
Leighton Paisner LLP

Tyler Mark, Bryan Cave Leighton
Paisner LLP

Exhibit A

MATERIAL U.S. FEDERAL INCOME TAX CONSEQUENCES

The following are the material
U.S. federal income tax consequences (i) of the Spinco Distribution and the Merger to U.S. Holders (as defined below) of Berry common
stock, and (ii) of the reverse stock split and the Merger to U.S. Holders of Glatfelter common stock. This discussion is based on the
Code, applicable Treasury regulations, administrative interpretations and court decisions as in effect as of the date of this document,
all of which may change, possibly with retroactive effect. For purposes of this discussion, a "U.S. Holder" is a beneficial
owner of Berry common stock or Glatfelter common stock, as applicable, that is for U.S. federal income tax purposes:

 · an individual who is a citizen or resident of the United States;

 · a corporation, or other entity taxable as a corporation for U.S. federal income tax purposes, created
or organized in or under the laws of the United States, any state therein or the District of Columbia;

 · an estate the income of which is subject to U.S. federal income taxation regardless of its source; or

 · a trust if (1) a U.S. court is able to exercise primary supervision over the administration of the trust
and one or more U.S. persons have the authority to control all substantial decisions of the trust or (2) the trust has a valid election
in effect to be treated as a U.S. person for U.S. federal income tax purposes.

This discussion assumes that U.S.
Holders of Berry common stock or Glatfelter common stock, as applicable, hold such stock as a capital asset for tax purposes (generally,
assets held for investment). It does not address all aspects of U.S. federal income taxation that may be important to a U.S. Holder in
light of that stockholder's particular circumstances or to a U.S. Holder subject to special rules, such as:

 · a financial institution, regulated investment company, real estate investment trust or insurance company;

 · a tax-exempt organization;

 · a dealer or broker in securities, commodities or foreign currencies;

 · a stockholder that holds Berry common stock or Glatfelter common stock, as applicable, as part of a hedge,
appreciated financial position, straddle, conversion or other risk reduction transaction;

 · a stockholder that holds Berry common stock or Glatfelter common stock, as applicable, in a tax-deferred
account, such as an individual retirement account or a plan qualifying under Section 401(k) of the Code; or

 · a stockholder that acquired Berry common stock or Glatfelter common stock, as applicable, pursuant to
the exercise of options or similar derivative securities or otherwise as compensation.

If a partnership, or any entity
or arrangement treated as a partnership for U.S. federal income tax purposes, holds Berry common stock or Glatfelter common stock, the
tax treatment of a partner in such partnership generally will depend on the status of the partners and the activities of the partnership.
A partner in a partnership holding Berry common stock or Glatfelter common stock should consult its own tax advisor.

This discussion of material U.S. federal
income tax consequences does not address all potential U.S. federal income tax consequences of the Spinco Distribution, the Merger and
the reverse stock split, including consequences that may depend on individual circumstances. In addition, it does not address any estate,
gift or other non-income tax consequences, any tax consequences arising under the Medicare contribution tax on net investment income or
the alternative minimum tax or any foreign, state or local tax consequences of the Spinco Distribution, the Merger and the reverse stock
split. Each holder of Berry common stock should consult its own tax advisor as to the particular U.S. federal, state or local or foreign
income or other tax consequences of the Spinco Distribution and the Merger to such holder. Each holder of Glatfelter common stock should
consult its own tax advisor as to the particular U.S. federal, state or local or foreign income or other tax consequences of the reverse
stock split and the Merger to such holder.

    1

Tax
Opinions and IRS Ruling

The completion of the Initial
Spin, the Spinco Distribution, the Merger and certain related Transactions are conditioned upon the receipt by Berry, with a copy to
Glatfelter, of (1) Tax Opinions from its tax counsel substantially to the effect that, among other things, for U.S. federal income
tax purposes, (a) the Initial Spin, taken together with certain related Transactions, will qualify as a "reorganization"
under Section 368(a)(1)(D) of the Code and a tax-free distribution under Section 355 of the Code, (b) the Spinco
Distribution will qualify as a tax-free distribution under Section 355 of the Code and (c) the Merger will qualify as a "reorganization"
under Section 368(a) of the Code, and (2) the IRS Ruling regarding the qualification of the Contribution, the Initial
Spin, the Spinco Distribution, the Special Cash Payment and certain related Transactions for tax-free treatment.

In rendering the Tax Opinions,
Berry's tax counsel will rely on, among other things, (1) customary representations and covenants made by Berry, Spinco and Glatfelter,
(2) specified assumptions, including an assumption regarding the completion of the Initial Spin, the Spinco Distribution, the Merger
and certain related Transactions in the manner contemplated by the Transaction Documents and (3) the IRS Ruling. If any of those
representations, covenants or assumptions is inaccurate, or the facts upon which the Tax Opinions will be based are materially different
from the facts at the time of the Initial Spin or the Spinco Distribution, the conclusions expressed in the Tax Opinions may be incorrect
and the tax consequences of the Initial Spin, the Spinco Distribution and the Merger could differ from those described below. Opinions
of counsel are not binding on the IRS. As a result, to the extent a conclusion expressed in the Tax Opinions is not also covered in the
IRS Ruling, such conclusion could be challenged by the IRS, and if the IRS prevails in such challenge, the tax consequences to Berry
and its stockholders could be materially less favorable. Additionally, although the IRS Ruling is generally binding on the IRS, Berry,
Spinco and Glatfelter will not be able to rely on the IRS Ruling if the factual representations made to the IRS in connection with the
IRS Ruling request prove to be inaccurate or incomplete in any material respect, or if undertakings made to the IRS in connection with
the request for the IRS Ruling are not satisfied. If this were to occur, the Initial Spin and the Spinco Distribution may not qualify
(in whole or part) for tax-free treatment. As a result, the tax consequences to Berry and its stockholders could be materially less favorable.

Consequences
of the Spinco Distribution and the Merger to U.S. Holders of Berry Common Stock

The Spinco
Distribution

As
described above, the completion of the Spinco Distribution is conditioned upon the receipt by Berry, with a copy to Glatfelter, of an
IRS Ruling and a Tax Opinion from BCLP LLP substantially to the effect that,
among other things, for U.S. federal income tax purposes, the Spinco Distribution, taken together with certain related Transactions,
will qualify as a tax-free distribution under Section 355 of the Code, and the IRS Ruling regarding
the qualification of the Distribution and certain related Transactions for tax-free treatment, which Berry received from the
IRS on July 5, 2024. Provided If Berry
receives the IRS Ruling and the Tax Opinion, the Spinco Distribution, so
qualifies as a tax-free distribution, and the IRS Ruling and Tax Opinion continue to be valid, and in
full force and effect, then for U.S. federal income tax purposes:

 · The Spinco Distribution
                                            generally will not result in the recognition of income, gain or loss by Berry;

 · U.S. Holders of Berry
                                            common stock will not recognize income, gain or loss upon the receipt of Spinco common stock
                                            in the Spinco Distribution;

 · the aggregate tax basis
                                            of the shares of Spinco common stock distributed by way of a Spin-Off to a U.S. Holder of
                                            Berry common stock will be determined by allocating the aggregate tax basis of such U.S.
                                            Holder in the shares of Berry common stock with respect to which the pro rata distribution
                                            is made between such Berry common stock and the Spinco common stock received in proportion
                                            to the relative fair market values of each immediately following the Spinco Distribution;
                                            and

 · the holding period
                                            (for U.S. federal income tax purposes) of any shares of Spinco common stock received by a
                                            U.S. Holder of Berry common stock will include the holding period at the time of the completion
                                            of the Spinco Distribution of the shares of Berry common stock with respect to which the
                                            shares of Spinco common stock were received.

    2

In general, if the Spinco
Distribution were not to qualify as a tax-free distribution under Section 355 of the Code, each U.S. Holder who receives Spinco
common stock in the Spinco Distribution would generally be treated as receiving a taxable distribution equal to the fair market value
of the Spinco common stock received by such U.S. Holder in the Spinco Distribution. In the event that a U.S. Holder is treated as receiving
a taxable distribution in the Spinco Distribution, su