SecProbe.io

June 30 , 2016

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

 Re: Cooper -Standard  Holdings Inc.
  Form 10 -K for the Fiscal Year Ended December 31, 2015
  Filed February 23 , 2016
  File No. 0 -54305

Dear Mr. Edwards :

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so w e may
better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts  and circumstances, please tell us why in your response.

After reviewing the information you provide in response to this comment, we may have
additional comments.

General

1. You state on page 5 that Fiat Chrysler Automobiles, PSA Peugeot Citroën, and  the
Volkswagen Group are among your top customers.   We are aware of publicly available
information indicating that Fiat, Peugeot, and Volkswagen sell their vehicles in Sudan
and/or Syria, countries which are designated as state sponsors of terrorism by the S tate
Department and are subject to U.S. economic sanctions and export controls.   You do not
include disclosure about any contacts with Sudan or Syria.   Please describe to us the
nature and extent of any past, current and anticipated contacts with Sudan and  Syria,
whether through subsidiaries, customers, distributors, or other direct or indirect
arrangements.   You should describe any products, technology and services you have
provided into Sudan and Syria, directly or indirectly, and any agreements, arrangem ents
or other contacts you have had with the governments of Sudan and Syria or entities they
control.

Jeffrey S. Edwards
Cooper -Standard Holdings Inc.
June 30 , 2016
Page 2

2. Please discuss the materiality of any contacts with Sudan and Syria you describe in
response to the comment above, and whether the contacts constitute a material
investment risk for your security holders.   You should address materiality in quantitative
terms, including the approximate dollar amounts of any revenues, assets and liabilities
associated with Sudan and Syria for the last three fiscal years and the subsequent interim
period.   Also, address materiality in terms of qualitative factors that a reasonable investor
would deem important in making an investment decision, including the potential impact
of corporate activities upon a company’s reputation a nd share value.   Various state and
municipal governments, universities and other investors have proposed or adopted
divestment or similar initiatives regarding investment in companies that do business with
U.S.-designated state sponsors of terrorism.   You should address the potential impact of
the investor sentiment evidenced by such actions directed toward companies that have
operations associated with Sudan and Syria.

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 Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to the company’s disclosu re, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 pr oceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202) 551 -
3470 if you have any questions about the comments or our review .

         Sincerely,

         /s/ Cecilia  Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

Jeffrey S. Edwards
Cooper -Standard Holdings Inc.
June 30 , 2016
Page 3

 cc:  Anne Nguyen Parker
  Assistant Director
 Division of Corporation Finance