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                          May 17, 2022

       Terrence Gohl
       President and Chief Executive Officer
       Horizon Global Corp
       47912 Halyard Drive
       Suite 100
       Plymouth, Michigan 48170

                                                        Re: Horizon Global Corp
                                                            Registration 
Statement on Form S-3
                                                            Filed May 11, 2022
                                                            File No. 333-264862

       Dear Mr. Gohl:

              This is to advise you that we have not reviewed and will not 
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for 
acceleration. 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 Gregory 
Herbers at 202-551-8028 with any questions.



                                                                                
                          Sincerely,

                                                                                
                          Division of Corporation Finance
                                                                                
                          Office of Manufacturing
       cc:                                              Michael Solecki