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January 7, 2019

ATTORNEYS AT LAW

 

777 East Wisconsin Avenue, Suite 3800

Milwaukee, Wisconsin 53202-5306

414.271.2400 TEL

414.297.4900 FAX

www.foley.com

 

WRITER’S DIRECT LINE

414.297.5596

pfetzer@foley.com EMAIL

 

Via Edgar

 

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 

 
Re:Cruiser Capital / Ashland Global

 

Ladies and Gentlemen:

 

On behalf of Cruiser Capital Advisors, LLC, Keith M. Rosenbloom, Cruiser Capital Master Fund LP, Metamorphosis IV LLC, Allen A. Spizzo, William H. Joyce, Patrick E. Gottschalk and Carol S. Eicher (the “Participants”), we are hereby transmitting for filing pursuant to Rule 14a-6 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), a definitive proxy statement and proxy card (under the cover page required by Rule 14a-6(m) and Schedule 14A of the Exchange Act) for use in conjunction with the 2019 annual meeting of Ashland Global Holdings Inc. (the “Annual Meeting”). The Participants are effecting this filing by direct transmission to the EDGAR System.

 

The only matters known by the Participants to be considered at the Annual Meeting are:

 

1.The election of directors;

 

2.A proposal to approve a non-binding advisory resolution approving the compensation paid to Ashland Global Holdings’ named executive officers; and

 

3.A proposal to ratify on an advisory (non-binding) basis the appointment of Ernst & Young LLP as Ashland Global Holdings’ independent registered public accounting firm for fiscal 2019.

 

Please call the undersigned at (414) 297-5596 should you have any questions regarding this filing.

 

Very truly yours,

/s/ Peter D. Fetzer

 

Peter D. Fetzer

 

Enclosures

 

AUSTIN

Boston

CHICAGO

dallas

DENVER

 

DETROIT

houston

JACKSONVILLE

LOS ANGELES

MADISON

 

MEXICO CITY

MIAMI

MILWAUKEE

NEW YORK

ORLANDO

 

SACRAMENTO

SAN DIEGO

SAN FRANCISCO

SILICON VALLEY

TALLAHASSEE

 

TAMPA

WASHINGTON, D.C.

BRUSSELS

TOKYO