SEC Comment Letter for Cooper-Standard Holdings Inc. (CPS) (CIK 0001320461) (CPS) — Jan 30, 2012

Cooper-Standard Holdings Inc. (CPS) (CIK 0001320461)
Date: Jan. 30, 2012 · CIK: 0001320461 · Accession: 0000000000-12-004873

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File numbers found in text: 000-54305

Date

January 30, 2012

Author

David R. Humphrey Accounting Branch Chief

Form

UPLOAD

Company

Cooper-Standard Holdings Inc. (CPS) (CIK 0001320461)

Letter

January 30, 2012 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 completed our review of your f iling. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or th e filing and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ David R. Humphrey
David R. Humphrey Accounting Branch Chief

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January 30, 2012
 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 completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
   /s/ David R. Humphrey
David R. Humphrey Accounting Branch Chief

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