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SEC Company Response from Cooper-Standard Holdings Inc. (CPS) (CIK 0001320461) (CPS) — Aug 25, 2011

Cooper-Standard Holdings Inc. (CPS) (CIK 0001320461)
Date: Aug. 25, 2011 · CIK: 0001320461 · Accession: 0001193125-11-231773

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File numbers found in text: 333-175637

Date
August 25, 2011
Author
Allen J. Campbell
Form
CORRESP
Company
Cooper-Standard Holdings Inc. (CPS) (CIK 0001320461)

Letter

Correspondence

World Headquarters

August 25, 2011

VIA EDGAR

Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Justin Dobbie

Re: Cooper-Standard Holdings Inc. (the “Company”)

Registration Statement on Form S-3 (File No. 333-175637)

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the Company requests that the effective date of the above-referenced Registration Statement on Form S-3 filed with the Securities and Exchange Commission (the “Commission”) on July 18, 2011 (as amended, the “Registration Statement”) be accelerated so that the Registration Statement will be declared effective at 3:00 P.M. Eastern Standard Time on August 26, 2011, or as soon thereafter as practicable.

In connection with this request, 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.

[Remainder of page intentionally left blank]

Very truly yours,
COOPER-STANDARD HOLDINGS INC.

Show Raw Text
CORRESP
1
filename1.htm

Correspondence

World Headquarters

 August 25, 2011

 VIA EDGAR

 Securities and Exchange Commission

100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: Justin Dobbie

Re:
Cooper-Standard Holdings Inc. (the “Company”)

 Registration Statement on Form S-3 (File No. 333-175637)

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the Company requests that the effective date
of the above-referenced Registration Statement on Form S-3 filed with the Securities and Exchange Commission (the “Commission”) on July 18, 2011 (as amended, the “Registration Statement”) be accelerated so that
the Registration Statement will be declared effective at 3:00 P.M. Eastern Standard Time on August 26, 2011, or as soon thereafter as practicable.

 In connection with this request, 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.

 [Remainder of page intentionally left blank]

Very truly yours,

COOPER-STANDARD HOLDINGS INC.

By:

 /s/ Allen J. Campbell

Name:

Allen J. Campbell

Title:

Chief Financial Officer