UNITED STATES
                                  SECURITIES AND EXCHANGE COMMISSION
                                               WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                                       March 6,
2020
  Douglas L. Dethy
  President
  D.C. Capital Advisors, Ltd.
  800 Third Avenue, 39th Floor
  New York, New York 10022

          Re:     Superior Industries International, Inc.
                  PRRN14A preliminary proxy statement filing made on Schedule
14A
                  Filed on March 5, 2020 by D.C. Capital Advisors, Ltd., et al.
                  File No. 001-06615

  Dear Mr. Dethy,

          We have reviewed the above-captioned filing, and have the following
comments. Some
  of our comments may ask for additional information so that we may better
understand the disclosure.

          Please respond by amending the filing and/or by providing the
requested information. After
  reviewing any amendment and any information provided in reply to these
comments, we may have
  additional comments. If you do not believe our comments apply to your facts
and circumstances,
  and/or do not believe an amendment is appropriate, please tell us why in a
written response.

  Amendment Number One to Preliminary Proxy Statement filed on Schedule 14A

  Letter to Stockholders

  1. The participants "believe the election of [their] nominee will be a
catalyst to change the
     boardroom dynamics that have hampered SUP's progress." Given that it
remains possible
     that the election of the nominee could adversely impact "boardroom
dynamics" to the extent
     any opposition or resistance to the Board's policies or plans are
enunciated, please qualify
     the cited representation that has been made to account for this
possibility and to state exactly
     how a single director may not only improve boardroom dynamics but also
inspire such
     improvement in the specific context cited. Alternatively, please delete
the representation.
  We Are Concerned that the Board is Not Adequately Aligned with Common
Stockholders, p. 14

  2. The participants believe the existing "independent directors lack a
meaningful vested
     financial interest in the common shares of the Company." The participants
also represent
     that "the Board needs to be refreshed with new, independent and objective
perspectives,
     including the addition of a stockholder representative on the Board that
is aligned with the
     common stockholders." Please revise to identify the specific misalignment,
or remove the
     implication that the existing Board has misaligned interests. Given the
participants' nominee
     owns 32,500 shares, please remove the impression that his addition to the
Board would add a
     representative who holds a "meaningful vested financial interest in the
common shares..."
 Douglas L. Dethy
D.C. Capital Advisors, Ltd.
March 6, 2020
Page 2

The Nominee, page 16

3. The disclosure indicates D.C. Capital believes the nominee "would be, an
`independent
   director' within the meaning of (i) applicable New York Stock Exchange
listing standards
   applicable to board composition..." Notwithstanding the participant's
belief, disclosure
   elsewhere in the proxy statement and related letter to stockholders
characterizes the nominee
   as already being "independent." Under the NYSE's listing standards, a
director is not
   deemed to be independent unless the Board first determines, based on
subjective criteria, that
   such director is independent. Accordingly, the participants should revise to
remove the
   implication that a conclusion already has been reached. In addition, the
participants should
   disclose that even if they believe that the Board is likely to determine
that the nominee is
   independent under the NYSE listing standards, ultimately, the determination
of such person's
   independence rests with the judgment and discretion of the Board.

Solicitation of Pries, page 22
4. The current disclosure omits any reference to any of the following
additional participants as
   being involved in the solicitation of proxies from the Company's
stockholders: D.C. Capital
   Advisors, D.C.R. Partners, Mr. Dethy, and Mr. Benvenuti. Further, Item
4(b)(2) of Schedule
   14A requires the disclosure of the class or classes of employees of any
participant in the
   solicitation that will be involved in the solicitation of stockholders. The
participants should
   disclose which class or classes of employees of the participants have been
enlisted to conduct
   the solicitation, including the employees of D.C. Capital Partners, D.C.
Capital Advisors, and
   D.C.R. Partners and the manner and nature of their employment for such
purpose.
   Alternatively, notwithstanding the permissibility of not disclosing negative
responses
   pursuant to Rule 14a-5(a), please confirm that no such persons will be
soliciting any proxies.

        We remind you that the participants are responsible for the accuracy
and adequacy of
    their disclosures, notwithstanding any review, comments, action or inaction
by the staff.

        You may contact me at (202) 551-3266 with any questions.


                                                            Sincerely,

                                                            /s/ Nicholas P.
Panos

                                                            Nicholas P. Panos
                                                            Senior Special
Counsel
                                                            Office of Mergers &
Acquisitions

 cc:    Elizabeth Gonzalez-Sussman, Esq.