May 24, 2018

Suping Lu
Sole Director
Garrett Transportation Systems Inc.
La Piece 16
Rolle, Switzerland

       Re: Garrett Transportation Systems Inc.
           Draft Registration Statement on Form 10
           Submitted May 1, 2018
           CIK No: 0001735707

Dear Mr. Lu:

       We have reviewed your draft registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so we may
understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional

Registration Statement on Form 10

Exhibit 99.1
The Spin-Off, page 1

1.     You disclose that the reason the company is undertaking the separation
is to permit "a
       more focused business" that will be better able to invest in growth
opportunities and
       execute its strategic plans. Please briefly describe major differences
in strategy, operating
       priorities and business focus between Honeywell and Garrett.
 Suping Lu
FirstName LastNameSuping LuInc.
Garrett Transportation Systems
Comapany NameGarrett Transportation Systems Inc.
May 24, 2018
May 24, 2018 Page 2
Page 2
FirstName LastName
Our Company, page 2

2.       Please clarify whether the distribution network of 160 distributors
covering 180 countries
         will continue to be contractually obligated to the company, as opposed
to Honeywell,
         following the separation.
Our Industry, page 3

3.       Please revise the disclosure throughout this section regarding CAGR
for various aspects
         of your business to include balancing language stating that there is
no guarantee that you
         will achieve comparable CAGR metrics in the future.
Attractive Financial Profile , page 8

4.       Please balance your disclosure regarding the topline forecast to note
that the expected
         growth is subject to the obligations of the Indemnification and
Reimbursement Agreement
         and other currently unquantifiable risks to the business.
Questions and Answers about the Spin-Off
Will SpinCo incur any debt prior to or at the time of the Distribution?, page

5.       When the information is available, please revise this Question and
Answer to quantify the
         amount of the indebtedness that you expect to incur.
Risk Factors
We are subject to risks related to the Indemnification and Reimbursement
Agreement, page 20

6.       Please expand this risk factor to include information regarding the
covered amount of
         asbestos liability payments made in the past, to permit investors to
understand the
         potential future liability.
Our products and services depend in part on intellectual property and
technology licensed from
third parties, page 24

7.       We note your disclosure that much of your business and many of your
products rely on
         key technologies developed or licensed from third parties. Please
disclose your
         accounting policy for your technologies licensed from third parties.
Your percentage ownership in SpinCo may be diluted in the future, page 32

8.       Please revise this risk factor to include information concerning
plans, if any, to issue
         equity awards to directors, officers and other employees, as well as
any acquisitions or
         capital market transactions you are presently considering.
 Suping Lu
FirstName LastNameSuping LuInc.
Garrett Transportation Systems
Comapany NameGarrett Transportation Systems Inc.
May 24, 2018
May 24, 2018 Page 3
Page 3
FirstName LastName
The Spin-Off
Reasons for the Spin-Off, page 37

9.       Please disclose which party will bear the costs of the spin-off.
10.      We note your disclosure that the board considered alternatives to the
spin-off. Please
         disclose what alternatives the board considered, and the reasons that
the alternatives were
         not pursued.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page

11.      We note from your disclosure on page 1 that prior to the completion of
the spin-off, you
         will enter into a Separation and Distribution Agreement and several
other agreements
         relative to the spin-off. Once the terms of these agreements have been
determined, please
         revise your disclosure in your MD&A section to discuss any significant
amounts and
         terms related to these agreements.
Combined Financial Statements, page F-1

12.      Please update the financial statements in accordance with Rule 3-12 of
Regulation S-X in
         your next amendment to Form 10.
Notes to Combined Financial Statements
Note 18. Commitments and Contingencies
Asbestos Matters, page F-26

13.      We note your disclosure that the liability for future claims
represents the estimated value
         of future asbestos-related bodily injury claims expected to be
asserted against you over the
         next five years. You say that in light of the uncertainties inherent
in making long-term
         projections, as well as certain factors unique to friction product
asbestos claims, you do
         not believe that you have a reasonable basis for estimating asbestos
claims beyond the
         next five years.

         ASC 450 does not provide bright lines with regard to time horizons in
which ASC 450
         judgments should be considered and applied. Therefore, we do not
believe there is a
         conceptual basis for limiting an ASC 450 assessment to a certain time
horizon. We
         believe your ASC 450 assessment should consider all claims without
limitation to a
         specific time period. It is unclear how the ASC 450 assessment was
considered for
         periods outside of the five year time horizons.

         Based on your history with asbestos claims, it seems unlikely to us
that the low end of
         your range of probable losses for time periods beyond five years is
zero. Therefore,
         please explain in greater detail how you determined that it was not
possible to make any
         estimate for probable losses (including any legal costs for claims
where an accrual has
 Suping Lu
Garrett Transportation Systems Inc.
May 24, 2018
Page 4
      already been provided) for periods beyond five years from the date of the
       You may contact Patrick Kuhn at 202-551-3308 or Andrew Mew at
202-551-3377 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Julie Griffith at 202-551-3267 or J. Nolan McWilliams at 202-551-3217
with any other

FirstName LastNameSuping Lu
                                                           Division of
Corporation Finance
Comapany NameGarrett Transportation Systems Inc.
                                                           Office of
Transportation and Leisure
May 24, 2018 Page 4
cc:       John C. Kennedy
FirstName LastName