Visteon Corporation One Village Center Drive Van Buren Township, MI 48111

December 12, 2011

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E., Mail Stop 3561

Washington, D.C. 20549-3561

Attention: Justin Dobbie, Legal Branch Chief

 

Re:		Visteon Corporation
		Pre-Effective Amendment No. 2 to Registration Statement on Form S-4
		Filed December 8, 2011
		File No. 333-177899

Dear Mr. Dobbie:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Visteon Corporation (the “Company”) hereby requests accelerated effectiveness of the above-captioned Pre-Effective Amendment No. 2 to Registration Statement to December 15, 2011 at 10:00 a.m., Eastern Time, or as soon as possible thereafter.

In connection with the foregoing request for acceleration of effectiveness, the Company hereby acknowledges the following:

 

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should the Securities and Exchange Commission (the “Commission”) or staff, acting pursuant to delegated authority, declare the filing effective, this does not foreclose the Commission from taking any action with respect to the filing;

 

•

the action of the Commission or staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 

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the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the securities laws of the United States.

Please contact Paul Zier of Kirkland & Ellis, LLP at (312) 862-2180 with any questions you may have concerning this request. In addition, please notify Mr. Zier when this request for acceleration has been granted.