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 March 19, 2025

Chris P. Gropp
Vice President and Chief Financial Officer
PHINIA Inc.
3000 University Drive
Auburn Hills, MI 48326

 Re: PHINIA Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Form 8-K Filed February 13, 2025
 File No. 001-41708
Dear Chris P. Gropp:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 29

1. We note your presentation of adjusted net earnings per diluted share on
page 32 and
 have the following comments:
 Please revise future filings to clearly identify this measure as a
non-GAAP
 measure. Refer to Rule 100(b) of Regulation G, along with the first
bullet point
 under Question 100.05 of our Compliance & Disclosure Interpretations
on Non-
 GAAP Financial Measures.
 We note you present "Adjusted earnings per diluted share" as a bold
heading
 within your analysis of Results of Operations on a consolidated
basis. Please
 revise future filings to first provide a bold heading and brief
discussion of GAAP
 earnings per diluted share to avoid giving prominence to the non-GAAP
measure.
 Refer to Item 10(e)(1)(i)(A) of Regulation S-K, along with the fourth
bullet point
 under Question 102.10(a) of our Compliance & Disclosure
Interpretations
 March 19, 2025
Page 2

 on Non-GAAP Financial Measures.
 The introductory sentence above your reconciliation indicates that
the adjusting
 items in this non-GAAP measure are "not reflective of the Company's
ongoing
 operations." Since the line item titled "intangibles amortization
expense" appears
 to represent normal, recurring amortization of certain intangible
assets with 14-15
 year useful lives, your current disclosure does not appear to fully
explain why you
 believe this non-GAAP measure provides useful information to your
investors.
 Please refer to Item 10(e)(1)(i)(C) of Regulation S-K and revise
future filings
 accordingly.
 We note you provide on page 4 some broad statements regarding
non-GAAP
 financial measures contained in your Form 10-K. To the extent these
disclosures
 are intended to satisfy any of the disclosure requirements of Item
10(e) of
 Regulation S-K for your presentation of adjusted net earnings per
diluted share on
 page 32, for the ease of your investors, please revise future
filings to either
 provide a cross-reference to your disclosures on page 4 or consider
moving the
 disclosures that currently appear on page 4 to be in close proximity
to your
 presentation of adjusted net earnings per diluted share on page 32.
Liquidity and Capital Resources, page 33

2. We note your analysis of cash flows from operating activities on page
34. Please
 revise future filings to provide a more informative discussion and
analysis of cash
 flows from operating activities, including changes in working capital
components, for
 the periods presented. In doing so, explain the underlying reasons and
implications of
 material changes between periods to provide investors with an
understanding of trends
 and variability in cash flows. Also ensure that your disclosures are not
merely a
 recitation of changes evident from the cash flow statements. Refer to
Item 303(a) of
 Regulation S-K and Section IV.B. of SEC Release No. 33-8350.
Form 8-K Filed February 13, 2025
Exhibit 99.1, page 1

3. We note the presentation of various non-GAAP financial measures within
your
 earnings release and have the following comments:
 Please tell us where you have made the disclosures required by Item
 10(e)(1)(i)(C) of Regulation S-K, or revise future earnings releases
to clearly
 provide such disclosures. If the definition of each non-GAAP measure
seen on
 pages 9-10 is intended to satisfy this requirement, please revise
future earnings
 releases to better explain why each non-GAAP measure provides useful
 information to your investors. To the extent any such explanation
indicates the
 adjustments are for items "not reflective of the Company's ongoing
operations"
 but the adjustments include normal, recurring amortization expense,
please revise
 future earnings releases to provide a more robust explanation that
addresses why
 you believe the exclusion of amortization expense provides useful
information to
 your investors.
 We note that several of your non-GAAP measures include adjustments
for
 March 19, 2025
Page 3

 "separation and transaction costs" and "(gains) losses for other
one-time events."
 We further note that the exact nature of these items is not
immediately apparent
 from their titles, such that additional narrative may be needed to
clarify what these
 adjustments represent. Please revise future earnings releases to
provide your
 investors with additional detail about the nature of these
adjustments, such as the
 additional context and descriptions provided within Note 4 to the
audited financial
 statements in your Form 10-K.

 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.

 Please contact Jennifer Thompson at 202-551-3737 or Hugh West at
202-551-3872
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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