SecProbe.io

August 28 , 2013

Via E -mail
William T. Gallagher
Senior Vice President, Secretary and General Counsel
Crown Holdings, Inc.
One Crown Way
Philadelphia, Pennsylvania 19154

Re: Crown Holdings, Inc.
  Registration Statement on Form S-4
Filed  August 16, 2013
  File No.  333-190694

Dear Mr. Gallagher :

We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

Summary, page 1

Expiration Date, page 3

1. We note that you have left blank the expiration date of the offer pending effectiveness of
this registration statement.  Please confirm supplementally that the offer will be o pen for
at least twenty full business days to ensure compliance with Rule 14e -1(a).  Please note
that pursuant to Rule 14d -1(b)(7), the 20th business day ends at twelve midnight eastern
time on the 20th business day and the offer must remain open continuou sly until at least
that time. Finally, please confirm that the expiration date will be included in the final
prospectus disseminated to security holders and filed pursuant to the applicable
provisions of Rule 424.

William T. Gallagher
Crown Holdings, Inc.
August 28 , 2013
Page 2

 Undertakings, page II -7

2. Please revise y our disclosure to include Item 512(a)(5)(ii) of Regulation S -K
undertakings.

Exhibits

3. Please file the organizational documents for all registrants, including guarantors.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request accelera tion of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility fo r
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting accelerati on are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequat e time  for us to review any amendment prior to the requested effective date of the
registration statement.

William T. Gallagher
Crown Holdings, Inc.
August 28 , 2013
Page 3

 Please contact Asia Timmons -Pierce, Staff Attorney,  at 202-551-3754  or Craig Slivka ,
Special Counsel,  at 202-551-3729  with any other questi ons.

Sincerely,

/s/ Craig Slivka, for

 Pamela Long
Assistant Director