SecProbe.io

August 19, 2011
 Via E-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.
  Amendment No. 1 to Registra tion Statement on Form S-3
Filed August 17, 2011
  File No. 333-175637

Dear Mr. Hefferon:
 We have reviewed your responses to the comm ents in our letter dated August 2, 2011 and
have the following additional comment.  All page numbers below correspond to the marked
version of your filing.  Selling Security Holders, page 15

1. We note your response to our prior comment one and reissue in part.  In footnotes 6 and
12, please revise to identify th e individual or individuals w ho have voting or investment
power with respect to the shares held by the legal entities identified in your selling
security holders table.  Refer to Regulati on S-K Compliance & Disclosure Interpretations
140.02 and 240.04.

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;

Timothy W. Hefferon, Esq. Cooper-Standard Holdings Inc. August 19, 2011 Page 2

  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.
 Please contact Sonia Bednarowski at (202) 551-3666 or me at (202) 551-3469 with any
questions.
Sincerely,
   /s/ Justin Dobbie
Justin Dobbie Legal Branch Chief
cc: Via E-mail

 Larry A. Barden, Esq.  Sidley Austin LLP