SecProbe.io

August 25, 2010

VIA U.S.  MAIL

Timothy W. Hefferon, Esq.  Vice President, General Counsel, and Secretary
Cooper-Standard Holdings, Inc.  39550 Orchard Hill Place Drive  Novi, MI 48375
Re: Cooper-Standard Holdings, Inc.
  Registration Statement on Form S-1
Filed July 26, 2010
  File No. 333-168316

Dear Mr. Hefferon:
 We have limited our review of your registra tion 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 beli eve 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 re gistration statement and the information you
provide in response to these comments, we may have additional comments.

Form S-1

General

1. As you know, Ernst & Young has advised us of certain matters that may impact its
independence with regard to its audits and re views of your financial statements.  In your
registration statement, please disclose these ma tters, the consideration of these matters by
your audit committee, and how the audit comm ittee reached a conclusion regarding Ernst
& Young’s ability to serv e as your auditor.

2. Please file the legal opinion prior to effectiveness.  Please allow sufficient time for staff
review as we may have comment  upon review of the opinion.

 Timothy W. Hefferon, Esq.
 Cooper-Standard Holdings, Inc.   August 25, 2010   Page 2
 Registration Statement cover page

3. Please revise the fee table to register a bona fide estimate of the payment in kind interest
and pay the applicable fee or advise.

Other

4. The financial statements should be updated, as  necessary, to comply with Article 3-12 of
Regulation S-X, at the effective da te of the registration statement.

5. Please provide a currently dated and signed consent from the independent registered public
accounting firm in the amendment.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission 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 for
the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments a nd 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 re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

 Timothy W. Hefferon, Esq.
 Cooper-Standard Holdings, Inc.   August 25, 2010   Page 3
 You may contact Juan Migone  at (202) 551-3312 or Da ve Humphrey, Accounting
Branch Chief at (202) 551-3211 if you have que stions regarding comments on the financial
statements and related matters.  Please contact J. Nolan McWilliams at (202) 551-3217 or me at
(202) 551-3412 with any other questions.
Sincerely,

        A m a n d a  R a v i t z          L e g a l  B r a n c h  C h i e f    cc: Via facsimile (212) 859-4000   Daniel J. Bursky, Esq.   Fried, Frank, Harris, Shriver & Jacobson LLP