SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
                  WASHINGTON, D.C. 20549

      DIVISION OF
CORPORATION FINANCE

September 17, 2013

Via E -mail
Kevin P. Clark
Executive Vice President and Chief Financial Officer
Delphi Automotive PLC
Courteney Road, H oath Way
Gillingham, Kent ME8 0RU
United Kingdom

 Re: Delphi Automotive PLC
  Form 10 -K for the Fiscal Year Ended December 31, 2012
  Filed February 11, 2013
  File No. 1 -35346

Dear Mr. Clark:

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comment.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to prov ide us with information so we may
better understand your disclosure.

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

After reviewing the information you provide in response to this comment, we may have
additional comments.

General
1. We are aware of publicly -available informatio n indicating that vehicles of several of your
largest customers, which you identify on page 9, are manufactured, assembled, and/or
sold in Cuba, Sudan, and/or Syria, countries which are designated as state spo nsors of
terrorism by the United States Departm ent of State  and are subject to U.S. economic
sanctions and export controls.   Your Form 10 -K does not include disclosure regarding
any contacts with Cuba, Sudan, or Syria.

Kevin P. Clark
Delphi Automotive PLC
September 17 , 2013
Page 2

 Please describe to us the nature and extent of any past, current, and anticipated c ontacts
with Cuba, Sudan, and  Syria, whether through direct or indirect arrangements .  Your
response should describe any products, components, equipment, tec hnology, or services
you have provided or anticipate providing, directly or indirectly, into Cuba, S udan, and
Syria , and any agreements, commercial arrangements, or other contacts you have had
with the governments of those countries or entities they control.
We urge all persons who are responsible  for the accuracy and adequacy o f the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to the co mpany’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202) 551 -
3470 if you have any questions about the comment or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Max Webb
  Assistant Director
 Division of Corporation Finance