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April 20, 2021
Allen Campbell
Chief Financial Officer
Verso Corp
8540 Gander Creek Drive
Miamisburg, Ohio 45342
Re:Verso Corp
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed March 1, 2021
File No. 001-34056
Dear Mr. Campbell:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2020
Note 1. Summary of Business and Basis of Presentation
Correction of previously reported amounts, page 56
1.We note that you corrected errors related to fiscal year 2019 consolidated financial
statements within your current Form 10-K.  You disclose the adjustments to correct
deferred tax assets were not material to your previously issued consolidated financial
statements based on your evaluation of both quantitative and qualitative factors.  In this
regard, please provide us with your materiality assessment which includes the
considerations outlined in SAB Topic IM as the adjustments to income tax benefit and net
income for fiscal year 2019 appear to be quantitatively material.

 FirstName LastNameAllen Campbell
 Comapany NameVerso Corp
 April 20, 2021 Page 2
 FirstName LastName
Allen Campbell
Verso Corp
April 20, 2021
Page 2
Note 15. Income taxes, page 73
2.We note that you reversed your deferred tax valuation allowance in fiscal 2019 after
considering the existence of recent cumulative income from continuing operations as a
source of positive evidence. We also note that you regularly review deferred tax assets for
recoverability based upon an analysis of all positive and negative evidence, including
expected future book income based on historical data and the expected timing of the
reversals of existing temporary differences. Please provide additional detail that supports
your decision to reverse the valuation allowance in fiscal 2019, including the nature of the
positive and negative evidence, as well as assumptions used in your analysis. Also,
provide similar information that supports your determination of the deferred tax valuation
allowance at December 31, 2020.
            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.
            You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Jean Yu,
Assistant Chief Accountant, at 202-551-3305 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing