June 21, 2018

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

       Re: Garrett Transportation Systems Inc.
           Amendment No. 1 to
           Draft Registration Statement on Form 10
           Submitted June 8, 2018
           CIK No: 0001735707

Dear Mr. Lu:

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

Amendment No. 1 to Form 10 filed June 8, 2018

Notes to Combined Financial Statements
Note 18. Commitments and Contingencies
Asbestos Matters, page F-27

1.     We note your response that you cannot reasonably estimate a liability
for claims not yet
       asserted for a period beyond five years because the amount of loss
cannot be reasonably
       estimated. Please tell us how and why you determined a five year time
period to estimate
 Suping Lu
Garrett Transportation Systems Inc.
June 21, 2018
Page 2
      losses for unasserted claims yields reliable estimates but time periods
beyond five years
      cannot be reasonably estimated. Specifically address how and why you
      trends over longer time periods are not more appropriate.
2.    We note your response that liability estimates for future claims were
developed with the
      assistance of a third party asbestos expert actuarial firm and outside
legal counsel and
      probable asbestos claims beyond the five-year period is not reasonably
      although Honeywell recognizes that it is probable that there will be
asbestos claims filed
      against Honeywell and that Honeywell will experience losses beyond the
      period. Please tell us whether you (1) attempted to estimate a liability
for potential claims
      beyond the five year period but concluded the resulting estimate of loss
(or range) was not
      reasonable or (2) did not attempt to estimate a liability beyond the five
year period
      because you believed you could not develop a reasonable estimate. If the
former, tell us
      the results of your estimation including your estimated liability (or
range thereof) as of
      December 31, 2017 and why you did not believe the estimate(s) to be
3.    Please quantify for us the amount of the liability at December 31, 2016
that relates to
      potential claims not yet asserted.
       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
June 21, 2018 Page 2
cc:       John C. Kennedy
FirstName LastName