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December 27, 2024

VIA EMAIL AND EDGAR

Christina Chalk and David Plattner

Special Counsel

Office of Mergers and Acquisitions

Division of Corporation Finance

United States Securities and Exchange
Commission

100 F Street, NE

Washington, D.C. 20549

 Re: Air Products & Chemicals, Inc.

Dear Ms. Chalk and Mr. Plattner:

We are writing on behalf of
our client, Mantle Ridge LP (“Mantle Ridge”), in response to Ms. Chalk’s telephonic request on December 26, 2024
that we provide Mantle Ridge’s previously filed analysis in support of statements made in certain materials recently filed by Mantle
Ridge with the United States Securities and Exchange Commission. The relevant portions of the presentation filed by Mantle Ridge1
including such analysis are attached hereto as Annex A. Going forward, Mantle Ridge will either include or cross-reference this
analysis when making such statements.

Please do not hesitate to
contact me at (212) 504-5757 with any questions or further comments you may have or if you wish to discuss the above.

Sincerely,

/s/ Richard Brand

Richard Brand, Esq.

Via e-mail:

cc: 	Stephen Fraidin, Cadwalader, Wickersham & Taft LLP

Gregory P. Patti, Jr., Cadwalader, Wickersham &
Taft LLP

1
See “Refreshing Air Products” (filed by Mantle Ridge) (Dec. 17, 2024)

(https://www.sec.gov/Archives/edgar/data/2969/000110465924129085/tm2428686d12_dfan14a.htm).

Annex A

Refreshed Board & New Leadership Entrenched Status Quo Operational and Financial Performance x Restore capital allocation discipline ,  pursuing projects consistent with the core  (including clean hydrogen, structured correctly)  Undisciplined capital allocation , pursuing high - risk, low - return non - core projects x High return on capital , with capital  discipline supported by skillful  underwriting and execution  Industry - worst return on capital  due to  mediocre returns on substantial capex  spend x Operational efficiency through reduction  in excess costs and core business  productivity  Poor operating performance vs. peers  driven by excess costs from projects  outside core and lesser productivity x Challenged projects should be objectively  derisked and optimized , with expertise,  transparency, and for maximum value  Various projects poorly underwritten and  executed , now claiming to pivot to clean  up in reaction to shareholder pressure Valuation and Shareholder Returns x Change agents have record of best - in - class  total shareholder returns , with opportunity  to deliver material upside  Industry - worst five - year TSR (50% vs. 93 - 171% for peers and 111%for  S&P 500) x Valuation multiple (P/E) upside (+ 15 - 20 % ) , on top of share price increase post - activism, to best - in - class  Valuation multiple (P/E) downside ( - 20%) potential, reflecting reversion to  wider discount to peer x Substantial value creation, with shares  worth ~$425 (present value), with durable,  low - risk,  long - term compounding  Significant value destruction likely to  persist, shares may revert to ~$245 based  on average discount over past year …Instilling Best - in - Class Capital and Operating Discipline, Driving  Substantial Shareholder Value 6

Air Products’ Shares Should Appreciate Significantly with  Confirmation of Upgraded Leadership and Governance Source: MR estimates. Current market valuation and consensus estimates per Bloomberg as of 12/12/2024. (1) Applies Unaffected Multiple (current LIN NTM multiple multiplied by APD's 1yr average multiple discount vs. LIN from unaffected date 10/4/2024) to consensus FY'25 EPS. (2) Applies LIN current NTM multiple to consensus APD FY'25 EPS +  Above - Peer CIP at 1x Book Value (3) Applies LIN current NTM multiple to run - rate impact of margin actions expected by FY'27 (discounted back to PV). Valuation Multiple ▪ Higher multiple with new  leadership (~15 - 20% upside) ▪ Close remaining multiple gap vs.  Linde; headline multiple  understates discount due to APD’s  above - peer CIP ($30/share); math  above assumes CIP valued at 1x BV Margin Expansion Realizable within 3 years, impact present valued : ▪ ~ $ 1 . 00 + EPS (~ 250 bps margin) from excess engineering and development costs tied to expanded scope of mega projects ▪ ~$0.50 - $1.50 EPS from ~100 - 300bps  of  margin opportunity, partially closing EBIT  margin and ROIC gap vs. Linde Enhanced Value of Above - Peer CIP ▪ Increase transparency  and enhance value of  Above - Peer CIP under  new leadership ▪ Assumes half turn  premium to BV (+0.5x) B C A We believe APD is worth ~$425+ (present value) under new leadership, with a long runway of  double - digit annual compounding Value Under New Leadership & Refreshed Board (Present Value per Share) $16 $423 $246 $65 $311 $54 $42 Status Quo¹ Shareholder  Influence Current  Price Valuation  Multiple² Margin  Expansion³ Enhanced  Value of  Above - Peer  CIP Value w/  New Leadership *Optimism for  upgraded CEO and  governance *Strategy pivot: APD  partially walking back  misguided strategy ~$425 ~$245 ~$55 Tightened multiple gap vs. Linde  (including a ~10% stock price  increase on MR announcement) ~$65 ~$310 ~$40 A B ~$15 C Upside from new leadership Sell - Side Commentary: " ... the stock could be worth $400+ if the activists succeed… If  current management prevails, we expect the stock to fall >20%." - Redburn Atlantic, 10/25/2024 Long - term,  steady,  double - digit  compounder 23

APD’s Shares Should Appreciate Significantly with Confirmation of  Upgraded Leadership and Governance Shares are worth $425+ (>35% upside, present value) under best - in - class leadership ▪ Upgrade leadership and  governance ▪ Optimize core industrial gas  business, including profitability ▪ Credibly and exclusively pursue  growth capex fitting within the  core industrial gas model ▪ Maximize value of ongoing  projects ▪ Increase transparency Valuation  Multiple 109 Excess Costs Related to  Scope Exp. of Projects Enhanced Value of  Construction - in - Progress Efficiency Opportunity  in Core  Business Upside Drivers Path Forward

 Air Products’ Shares Should Appreciate Significantly with  Confirmation of Upgraded Leadership and Governance Source: MR estimates. Current market valuation and consensus estimates per Bloomberg as of 12/12/2024. (1) Applies Unaffected Multiple (current LIN NTM multiple multiplied by APD's 1yr average multiple discount vs. LIN from unaffected date 10/4/2024) to consensus FY'25 EPS. (2) Applies LIN current NTM multiple to consensus APD FY'25 EPS +  Above - Peer CIP at 1x Book Value (3) Applies LIN current NTM multiple to run - rate impact of margin actions expected by FY'27 (discounted back to PV). Valuation Multiple ▪ Higher multiple with new  leadership (~15 - 20% upside) ▪ Close remaining multiple gap vs.  Linde; headline multiple  understates discount due to APD’s  above - peer CIP ($30/share); math  above assumes CIP valued at 1x BV Margin Expansion Realizable within 3 years, impact present valued : ▪ ~ $ 1 . 00 + EPS (~ 250 bps margin) from excess engineering and development costs tied to expanded scope of mega projects ▪ ~$0.50 - $1.50 EPS from ~100 - 300bps  of  margin opportunity, partially closing EBIT  margin and ROIC gap vs. Linde Enhanced Value of Above - Peer CIP ▪ Increase transparency  and enhance value of  Above - Peer CIP under  new leadership ▪ Assumes half turn  premium to BV (+0.5x) B C A We believe APD is worth ~$425+ (present value) under new leadership, with a long runway of  double - digit annual compounding Value Under New Leadership & Refreshed Board (Present Value per Share) $16 $423 $246 $65 $311 $54 $42 Status Quo¹ Shareholder  Influence Current  Price Valuation  Multiple² Margin  Expansion³ Enhanced  Value of  Above - Peer  CIP Value w/  New Leadership *Optimism for  upgraded CEO and  governance *Strategy pivot: APD  partially walking back  misguided strategy ~$425 ~$245 ~$55 Tightened multiple gap vs. Linde  (including a ~10% stock price  increase on MR announcement) ~$65 ~$310 ~$40 A B ~$15 C Upside from new leadership Sell - Side Commentary: " ... the stock could be worth $400+ if the activists succeed… If  current management prevails, we expect the stock to fall >20%." - Redburn Atlantic, 10/25/2024 Long - term,  steady,  double - digit  compounder 111