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 June 5, 2025

Jonathan Banas
Chief Financial Officer
Cooper-Standard Holdings Inc.
40300 Traditions Drive
Northville, MI 48168

 Re: Cooper-Standard Holdings Inc.
 Form 10-K for the Year Ended December 31, 2024
 Filed February 14, 2025
 File No. 001-36127
Dear Jonathan Banas:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Segment Results of Operations, page 33

1. We note your disclosure on page 34 of total segment adjusted EBITDA for
the
 reportable segments. We also note that this amount differs from the
consolidated
 Adjusted EBITDA disclosed on page 38 which is reconciled to your net
loss. Please
 note that a total of the segment profitability measures, when disclosed
outside the
 notes to the financial statements, represents a non-GAAP financial
measure and must
 be disclosed as such and be presented in accordance with our non-GAAP
guidance. In
 this regard, it appears that this amount may exclude some normal
recurring operating
 expenses. Please advise or revise accordingly. Refer to Question 104.04
of the SEC
 Staff's Compliance & Disclosure Interpretation on Non-GAAP Financial
Measures.
 June 5, 2025
Page 2

Liquidity and Capital Resources
Cash Flows, page 35

2. Please provide a more informative analysis and discussion of changes in
operating,
 investing, and financing cash flows for each period presented in future
filings. In
 doing so, explain the underlying reasons and implications of material
changes
 between periods to provide investors with an understanding of trends and
variability
 in cash flows. Ensure that your disclosures are not merely a recitation
of changes
 evident from the financial statements. Refer to Item 5.B.1 of Form 20-F
and Section
 IV.B of SEC Release No. 33-8350.
Notes to Consolidated Financial Statements
21. Business Segments, page 82

3. We note you include a line item in your reconciliation for consolidated
 EBITDA. Please note that as this does not appear to be a segment measure
of
 profitability, it would be considered a non-GAAP financial measure and
should not be
 disclosed in the notes to the financial statements in accordance with
Item
 10(e)(1)(ii)(C). We refer you to Comment 3 in our letter to you dated
May 21, 2024.
4. We note your line item of other segment items which you describe in
footnote (a) as
 including other income and expenses and other non-comparable items to
derive at
 total reportable segment adjusted EBITDA. Please provide us, and revise
future
 filings to include, a more detailed description of what is included in
the "other
 segment items". Refer to ASC 280-10-50-26B.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Melissa Gilmore at 202-551-3777 or Claire Erlanger at
202-551-3301
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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