Mail Stop 4628

                                                             December 18, 2018

Via E-mail
John P. Connolly
Chief Financial Officer
Platform Specialty Products Corporation
Merritt View Plaza
383 Main Avenue
Norwalk, CT 06851

       Re:     Platform Specialty Products Corporation
               Form 10-K for the Fiscal Year Ended December 31, 2017
               Filed February 28, 2018
               File No. 1-36272

Dear Mr. Connolly:

        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. In our comment, we ask you to provide us with information so
we may better
understand your disclosure.

       Please respond to the comment 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 our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to the comment, we may have additional
comments.

Risk Factors, page 15
We may be unable to ensure compliance with international trade restrictions and
economic
sanctions laws..., page 30

   1. You disclose that you do not conduct business in countries including
Syria and North
      Korea, but state that there can be no assurance that you have been at all
times in the past,
      or will be at all times in the future, in full compliance with sanctions
regarding those
      countries. We note that the Foreign Economic Boycotts section of the
Business Conduct
      and Ethics Policy on your website states that employees involved in
transactions with
      Syria and other identified countries must be on alert for requests
regarding the Israeli
      boycott. Also, Section 7.21 of the February 11, 2015 Amendment Agreement
filed as
      Exhibit 2.3 to your Form 8-K of the same date states that, following the
closing of the
 John P. Connolly
Platform Specialty Products Corporation
December 18, 2018
Page 2

       acquisition of Arysta LifeScience Ltd., the provision requiring
termination of business
       and operations in countries including Syria and Sudan will not be
applicable to business
       carried out pursuant to certain exemptions, exceptions, licenses or
authorizations.

       North Korea, Sudan and Syria are designated by the State Department as
state sponsors
       of terrorism, and are subject to U.S. economic sanctions and/or export
controls. Please
       describe to us the nature and extent of any past, current or anticipated
contacts with North
       Korea, Sudan and/or Syria, including contacts with their governments,
whether through
       subsidiaries, affiliates, distributors or other direct or indirect
arrangements.

        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.

        You may contact Jennifer Hardy, Special Counsel, at (202) 551-3767 or
me at (202) 551-
3470 if you have any questions about the comments or our review.

                                                            Sincerely,

                                                            /s/ Cecilia Blye

                                                            Cecilia Blye, Chief
                                                            Office of Global
Security Risk

cc:    Amanda Ravitz
       Assistant Director