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 June 30, 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
 Response Dated June 12, 2025
 File No. 001-36127
Dear Jonathan Banas:

 We have reviewed your June 12, 2025 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in
our June 5,
2025 letter.

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, page 33

1. We note from your response to our prior comment 1 that you will remove
the Total
 for reportable segments line item from the segment adjusted EBITDA
table in your
 MD&A as currently presented on page 34 of the Form 10-K, however you
propose to
 include additional line items for Corporate, eliminations and other
 and
 Consolidated Adjusted EBITDA as part of that same table. Please
note that we do
 not believe that presentation of these line items provides meaningful
information, as
 the segment measures are presented on a different basis from the
consolidated
 profitability measure. The "corporate, eliminations and other" line item
represents a
 reconciling item required by ASC 280-10-50-30 to be disclosed in the
footnotes to the
 June 30, 2025
Page 2

 financial statements to reconcile your segment profitability measures to
consolidated
 income before taxes. It does not appear appropriate to present this
amount outside of
 the ASC 280 disclosure, such as in MD&A as a reconciling item between
your
 segment measures and a non-GAAP consolidated measure.
 Please contact Melissa Gilmore at 202-551-3777 or Claire Erlanger at
202-551-3301
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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