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


     DIVISION OF
CORPORATION FINANCE


                                                                       February
20, 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.
                  PREC14A preliminary proxy statement filing made on Schedule
14A
                  Filed on February 19, 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 to this letter by amending the filing and/or by
providing the requested
  information. After reviewing any amendment to the filing 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.
  Preliminary Proxy Statement filed on Schedule 14A
  General
  1. Please advise us when the participants anticipate distributing their proxy
statement. Given
     that reliance on Rule 14a-5(c) is impermissible at any time before the
registrant distributes its
     proxy statement, the participants will accept all legal risk in connection
with distributing the
     initial definitive proxy statement without all required disclosures and
should undertake to
     subsequently provide any omitted information in a supplement in order to
mitigate that risk.
  Quorum; Broker Non-votes; Discretionary Voting, page 20
  2. Inconsistent disclosures in this section suggest that the possibility
remains that broker non-
     votes could exist. Please provide us with a brief legal analysis regarding
the permissibility of
     broker non-votes in the instant contested solicitation, or revise to
remove this inconsistency.
  Additional Participant Information, page 22
  3. Please refer to the following sentence on page 22: "Each participant in
this solicitation
     disclaims beneficial ownership of the shares of Common Stock that he or it
does not directly
     own." Advise us of the legal basis upon which beneficial ownership could
be disclaimed by
     such persons. Please refer to In re Coca Cola Co., Exchange Act Release
No. 13,655 (June
     21, 1977); and In re Douglas Kass, Exchange Act Release No. 31,046 (August
17, 1992).
 Douglas L. Dethy
D.C. Capital Advisors, Ltd.
February 20, 2020
Page 2


    Form of Proxy

4. Please refer to the following statement: "There is no assurance that any of
the candidates
   who have been nominated by the Company will serve as directors if our
Nominees are
   elected." Please revise to conform to the fact that the participants have
only nominated one
   director candidate.

        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.