SecProbe.io

December 28, 2011
 Via Email

Mr. Allen J. Campbell Chief Financial Officer 39550 Orchard Hill Place Drive
Novi, Michigan 48375

Re: Cooper-Standard Holdings Inc.
 Form 10-K for the year ended December 31, 2010
Filed March 21, 2011 File No. 000-54305

Dear Mr. Campbell:
 We have reviewed your filing and have the following comment.  We may ask you to
provide us with information so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.               Form 10-K for the year ended December 31, 2010

 Management’s Discussion and Analysis of Financial Condition

Results of Operations, page 38

1. Your disclosures on pages 20 and 52 indicate that raw materials comprise the largest
component of your costs, representing appr oximately 49% of your costs in 2010.  In
addition, you indicate that there have been ex treme fluctuations in material pricing in
recent years, and that higher than anticipate d material costs could adversely affect your
operating profitability if you could not recoup such costs through pri ce increases to your
customers.  However, your discussion and an alysis of cost of products sold does not
address your expenses directly. In this rega rd, your disclosures should be expanded to
include a discussion of these costs on a stand-alone basis.   Such disclosures should
clearly identify the major cost components incl uded in cost of products sold.  Further,
such disclosure should quantify and discuss the impact of each significant component of
costs comprising cost of products sold.  Materi ality should be assessed in relation to your
consolidated performance measures.  This disclosure should be presented in a manner

Mr. Allen J. Campbell Cooper-Standard Holdings Inc. December 28, 2011 Page 2

 which will allow investors to discern the relative contribution of each significant
component to the total change in cost of products sold.  In addition, the impact of individual material variances in components of cost of products sold should be separately
analyzed, disclosed, quantified, and discussed wi thout regard to the overall effect should
those variances be netted to offset each othe r.  Also, please ensure that your revised
disclosure provides appropriate explanation of underlying reasons for changes.  For
example, in addition to quantifying the impact s of changes in price and volume, explain
the underlying reasons for these changes.  Pleas e provide us with a copy of your intended
revised disclosure.  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 include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

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

You may contact Kristin Sh ifflett at 202-551-3381 if you have questions regarding
comments on the financial statements and rela ted matters.  Please contact me at 202-551-3211
with any other questions.
Sincerely,
   /s/ David R. Humphrey
David R. Humphrey Accounting Branch Chief