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CORRESP
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October 18, 2024

Ms. Jean Yu

Mr. Hugh West

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Superior Industries International,
Inc.

Form 10-K for the
Fiscal Year Ended December 31, 2023

Filed March 7, 2024

File No. 001-06615

Dear Ms. Yu and Mr. West,

This letter contains the responses of Superior
Industries International, Inc., a Delaware corporation (the “Company”), to your letter dated October 10, 2024, setting forth
comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) regarding
the above-referenced filing. For your convenience, we have restated each of the Staff’s comments and provided the Company’s
response below each comment.

Management’s Discussion
and Analysis of Financial Condition and Results of Operations

Non-GAAP Financial Measures, page
27

 1. We refer to your non-GAAP measure
                                            Adjusted EBITDA. We note from footnote (1) to the table on page 28, the adjustment for restructuring,
                                            factoring fees and other include $4.2 million of accounts receivable factoring fees and $8.1
                                            million of other restructuring-related costs, primarily related to advisor fees. Please explain
                                            to us in greater detail the nature of these costs as they appear to be normal, recurring
                                            operating costs. As part of your response, tell us how you considered the guidance outlined
                                            in Question 100.01 of the Division of Corporation Finance Compliance & Disclosure Interpretations
                                            on Non-GAAP Financial Measures in determining the adjustments are appropriate.

RESPONSE:

The Company respectfully
acknowledges the Staff’s comment and advises that it has considered the guidance in Question 100.01 of the Division of Corporation
Finance’s Compliance & Disclosure Interpretations (the “C&DIs”) on Non-GAAP Financial Measures. Question 100.01
states that certain adjustments, while not explicitly prohibited, could cause the presentation of non-GAAP financial information to be
misleading. It is also noted that Question 102.03 of the C&DIs provides that “[t]he fact that a registrant cannot describe
a charge or gain as nonrecurring, infrequent or unusual, however, does not mean that the registrant cannot adjust for that charge or
gain. Registrants can make adjustments they believe are appropriate, subject to Regulation G and the other requirements of Item 10(e)
of Regulation S-K.” Set forth below is a discussion of the nature of the Company’s factoring fees and other restructuring-related
costs, primarily related to advisor fees, the rationale for each of the adjustments, and the explanation of why such adjustments are
not misleading.

The Company further believes
disclosing, explaining, and reconciling these items as part of its presentation of Adjusted EBITDA provides a more complete understanding
of its ongoing operations, enhances comparability of current results to prior periods, and is useful for investors to analyze the Company’s
financial performance by eliminating the effects of certain items that may obscure trends in the underlying performance of the Company’s
business.

Factoring Fees

The Company maintains two
factoring programs for which the transfers of its accounts receivable qualify for sale accounting. The Company uses these factoring programs
as part of its corporate treasury cash management programs to manage the Company’s cash and liquidity needs. Additionally, the
Company has a $60.0 million revolving credit facility. The Company has historically not utilized its revolving credit facility; instead,
it has elected to factor its accounts receivable, as these factoring programs provide the Company with access to cash at costs that are
generally favorable as compared to borrowings under its revolving credit facility.

The decision to factor accounts
receivable is a centralized process made at the Company’s corporate headquarters and the fees associated with these programs are
presented in “Other income (expense), net” in the consolidated statement of income (loss), as the Company views such fees
as a cost of financing akin to interest expense, rather than a cost of operations. The Company believes these expenses are a component
of the expense of financing its business and thus, though recurring, are appropriately excluded from its Adjusted EBITDA measure, similar
to other costs of financing the business, so that investors can better understand the Company’s operating results, excluding the
costs of its financing arrangements.

Other restructuring-related
costs

The Company has excluded
certain non-recurring third-party advisor and consulting expenses related to its European Transformation project (as defined below),
as these costs are infrequent and outside the normal course of business. In its second quarter 2023 earnings release, the Company disclosed
its initiative to evaluate the European operations and take actions to reduce costs and increase the profitability of these operations
to be more in line with the North American operations. The Company began referring to this strategic initiative in its periodic filings
with the Commission as its European Transformation project.

In late 2022, prior to the
public announcement, the Company engaged a strategic consultant to evaluate its strategic alternatives in the European region, specifically
the rationalization of its German manufacturing plant, resizing the cost structure, and executing a profitability analysis of its aftermarket
business. The work completed within this phase of the project resulted in the Company making the decision to (i) enter its wholly owned
German subsidiary into a court-administered reorganization, effective August 31, 2023; (ii) move its manufacturing production capabilities
from Germany to Poland; and (iii) establish a shared service center in Poland to reduce administrative overhead.

The Company then engaged
a second consultant in early 2023 to help it prepare, execute, and project manage its plan to execute these specific strategic initiatives
in its European operations. The Company initiated these actions in the third quarter of 2023 and completed the transfer of production
to Poland in the second quarter of 2024. The Company expects to complete the right sizing of its cost structure in its European operations
in the second quarter of 2025, including the shared service center in Poland.

Lastly, there were various
other consultants and third-party advisors engaged by the Company to assist it in completing other aspects of the European Transformation
project, such as operational consultants to help stabilize the operations within its German plant prior to and during the court-administered
reorganization, and assist with the warehousing and inventory management of the safety and transitional stock needed during the plant
closure process.

While these costs have been
excluded from the Adjusted EBITDA calculations in multiple fiscal periods, they will only be incurred for a discrete period of time relating
to the European Transformation project. As a result, the Company believes these costs are not reflective of its ongoing operations and
affect the comparability of its operational results. Because of that, adjusting for them provides a more meaningful evaluation of its
current operating performance to prior periods and is consistent with the Staff’s guidance within Question 100.01 of the Compliance
& Disclosure Interpretations on Non-GAAP Financial Measures.

The Company acknowledges
the explanation provided herein contains greater detail than what has been provided in its disclosures historically. To the extent it
is material, the Company will provide additional detail on the nature of the projects and corresponding adjustments in future filings
as applicable.

Notes to the Consolidated Financial
Statements

Note 22 - Loss on Deconsolidation
of Subsidiary, page 61

 2. We note in August 2023, you deconsolidated
                                            your wholly owned subsidiary SPG as the company no longer controlled SPG due to its filing
                                            insolvency proceedings. As a result, you recognized a charge of $79.6 million during the
                                            third quarter, representing the difference of the carrying value over its fair value in your
                                            interest in and receivable from SPG. Please tell us whether there was any equity components
                                            previously recognized in accumulated other comprehensive income and how you considered such
                                            amounts in your calculation of gain or loss upon deconsolidation of SPG, including any reclassification
                                            from foreign currency transaction adjustments in accordance with ASC 810-10-40-4A. If so,
                                            please explain how such amounts were reflected within your statements of equity in accordance
                                            with ASC 830-30-40.

RESPONSE:

The Company acknowledges
the Staff’s comment and respectively advises the Staff that the Company did consider the equity components previously recognized
in accumulated other comprehensive income, specifically foreign currency translation adjustment, in its calculation of the loss on the
deconsolidation of SPG in accordance with ASC 810-10-40-4A. The amount was reclassified out of accumulated other comprehensive income
in accordance with ASC 830-30-40 and recognized as an increase to the “Loss on deconsolidation of subsidiary”, which amounted
to $79.6 million, in the consolidated statement of income (loss) during the year ended December 31, 2023. This amount was disclosed as
part of the “Net foreign currency translation adjustment” of $27.7 million in the consolidated statement of stockholders’
equity (deficit) for the year ended December 31, 2023 and was deemed to be immaterial (less than $500,000) for presentation as a separate
line item in the Company’s 2023 Form 10-K.

* 	 *	 *

We would be pleased to discuss any of
our responses with you if it would assist you or your team. Please do not hesitate to contact the undersigned at dlee@supind.com.

Very truly yours,

    /s/ Daniel D. Lee

    Daniel D. Lee

    Senior Vice President and Chief
Financial Officer