SecProbe.io

August 8, 2013

Via E -mail
Jeffrey S. Edwards
Chairman and Chief Executive Officer
Cooper -Standard Holdings Inc.
39550 Orchard Hill Place Drive
Novi, MI 48375

Re: Cooper -Standard Holdings Inc .
  Registration Statement on Form S-3
Filed  July 16, 2013
  File No.  333-189981

Dear Mr. Edwards :

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.

General

1. Please confirm your understanding that resales of shares issued as payment in -kind
dividends are not covered by this registration statement.  We note your disclosure in the
carryover paragraph on pages 12 -13.  Alternatively, please register the payment in -kind
dividend shares.

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.

 Jeffrey S. Edwards
 Cooper -Standard Holdings Inc.
 August 8, 2013
 Page 2

 Notwithstandin g our comments, in the event you request acceleration 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 auth ority, 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 for
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 reques ts 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 acceleration 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
adequate time  for us to review any amendment prior to the requested effective  date of the
registration statement.

Please contact J. Nolan McWilliams  at (202) 551 -3217  or me at (202) 551 -3642  with any
questions  you may have .

Sincerely,

/s/ Loan Lauren P. Nguyen

Loan Lauren P. Nguyen
Special Counsel

cc: Kevin F. Blatchford, Esq.
 Sidley Austin L LP