SEC Company Response from Cooper-Standard Holdings Inc. (CPS) (CIK 0001320461) (CPS) — Nov 19, 2010
Cooper-Standard Holdings Inc. (CPS) (CIK 0001320461)
Date: Nov. 19, 2010 · CIK: 0001320461 · Accession: 0001193125-10-265286
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File numbers found in text: 333-168316
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CORRESP 1 filename1.htm Correspondence Cooper-Standard Holdings Inc. 39550 Orchard Hill Place Drive Novi, MI 48375 Tel: (248) 596-5900 November 19, 2010 Via Electronic Transmission United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Justin T. Dobbie Re: Cooper-Standard Holdings Inc. Registration Statement on Form S-1 (File No. 333-168316) Dear Mr. Dobbie: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), Cooper-Standard Holdings Inc., a Delaware corporation (the “Company”), hereby requests that the effective date of the above-referenced Registration Statement on Form S-1 filed with the Securities and Exchange Commission (the “Commission”) on July 26, 2010 (as amended, the “Registration Statement”) be accelerated so that the Registration Statement may become effective at 4:00p.m., Eastern Standard Time, on November 23, 2010, or as soon thereafter as it is practicable. The Company acknowledges that: • should the Commission or the staff, acting pursuant to delegated authority, 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. Very truly yours, COOPER-STANDARD HOLDINGS INC. By: /s/ Timothy W. Hefferon Name: Timothy W. Hefferon, Esq. Title: Vice President, General Counsel and Secretary