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CORRESP
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CORRESP

 555 Eleventh Street, N.W., Suite 1000

Washington, D.C. 20004-1304

 Tel: +1.202.637.2200 Fax:
+1.202.637.2201

 www.lw.com

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 Washington, D.C.

 February 1, 2021

Via EDGAR

 Securities and Exchange Commission

 Division of Corporate Finance

 100 F Street, N.E.

Washington, D.C. 20549

Attention:        Erin Purnell

  Jay Ingram

  Dale Welcome

  John Cash

Re:
 Atotech Limited

Registration Statement on Form F-1 (Registration No. 333- 235928)

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, we attach the requests of our client, Atotech Limited (the “Company”), and of the underwriters that the effective date of the Company’s Registration Statement on Form F-1 (File No. 333-235928) be accelerated to 3:00 p.m., Washington D.C. time, on February 3, 2021, or as soon as practicable thereafter. We ask, however, that the
Securities and Exchange Commission staff not accelerate such effective date until we speak with you on that date.

 Please direct any
questions or comments regarding the foregoing to me at (202) 637-1028 or my colleague, Jason M. Licht, at (202) 637-2258.

Very truly yours,

 /s/ Patrick H. Shannon

Patrick H. Shannon

of LATHAM & WATKINS LLP

 cc:        Jason M. Licht, Latham & Watkins LLP

 Atotech Limited

William Street, West Bromwich

 West
Midlands, B70 0BG

 United Kingdom

February 1, 2021

 Via EDGAR

Securities and Exchange Commission

 Division of Corporate
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Attention:        Erin Purnell

     Jay Ingram

     Dale Welcome

     John Cash

Re:        Atotech Limited

    Registration Statement on Form F-1 (Registration No. 333- 235928)

 Ladies and Gentlemen:

 Pursuant to
Rule 461 under the Securities Act of 1933, as amended, Atotech Limited (the “Company”) hereby respectfully requests that the effective date of the Company’s Registration Statement on Form
F-1 (File No. 333-235928) be accelerated by the Securities and Exchange Commission to 3:00 p.m., Washington D.C. time, on February 3, 2021 or as soon as
practicable thereafter.

 *    *    *    *

 The Company requests that we be notified of such effectiveness by a telephone call to
Patrick Shannon of Latham & Watkins LLP at (202) 637-1028 or to Jason Licht of Latham & Watkins LLP at (202) 637-2258 and that such effectiveness
also be confirmed in writing.

Very truly yours,

Atotech Limited

 /s/ Geoff Wild

Name:

Geoff Wild

Title:

Chief Executive Officer

 cc:         Josh McMorrow, Secretary and General Counsel

    Patrick H. Shannon, Latham & Watkins LLP

    Jason M. Licht, Latham & Watkins LLP

 Citigroup Global Markets Inc.

388 Greenwich Street

 New York, NY 10013

Credit Suisse Securities (USA) LLC

 Eleven Madison Avenue

New York, NY 10011

 BofA Securities, Inc.

One Bryant Park

 New York, NY 10036

J.P. Morgan Securities LLC

 383 Madison Avenue

New York, NY 10179

 February 1, 2021

VIA EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

Attn:
 Erin Purnell

 Jay Ingram

 Dale Welcome

 John Cash

Re:        Atotech Limited

  Registration Statement on Form F-1

  Request for Acceleration of Effective Date

Ladies and Gentlemen:

 In accordance with
Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Atotech Limited (the “Registrant”)
that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form F-1 to become effective on
February 3, 2021, at 3:00 PM, Eastern Time, or as soon thereafter as is practicable, or at such later time as the Registrant or its outside counsel, Latham & Watkins LLP, may orally request via telephone call to the staff of the
Commission.

 Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that there will be
distributed to each Underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of
the preliminary prospectus.

 We, the undersigned, as representatives of the several underwriters, have complied and will comply, and we
have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [Signature page follows]

Very truly yours,

Citigroup Global Markets Inc.

Credit Suisse Securities (USA) LLC

BofA Securities, Inc.

J.P. Morgan Securities LLC

As representatives of the several Underwriters

Citigroup Global Markets Inc.

By:

 /s/ Paul Smith

Name: Paul Smith

Title: Managing Director

Credit Suisse Securities (USA) LLC

By:

 /s/ Christian M. Bradeen

Name: Christian M. Bradeen

Title: Managing Director

BofA Securities, Inc.

By:

 /s/ Greg Kelly

Name: Greg Kelly

Title: Managing Director

J.P. Morgan Securities LLC

 By:

 /s/ Manoj Vemula

 Name: Manoj Vemula

 Title: Managing Director

 [Signature Page to Underwriters’ Acceleration Request]