Amendment No. 3 to Registration Statement on Form S-1

Filed October 30, 2014

File No. 333-198271

Dear Mr. Ingram:

On behalf of our client, Axalta Coating Systems Ltd., a Bermuda exempted limited liability company (the “Company”), and pursuant to the applicable provisions of the Securities Act of 1933, as amended, and the rules promulgated thereunder, we are transmitting this letter in response to the comment received from the staff (the “Staff”) of the Securities and Exchange Commission by letter dated November 4, 2014 with respect to the above-captioned Registration Statement on Form S-1 of the Company.

The numbered paragraph in italics below sets forth the Staff’s comment together with the Company’s response. For the Staff’s convenience, we are also sending, by courier, copies of this letter.

General

Response: The Company respectfully notes the Staff’s comment and advises the Staff that its financial closing procedures for the quarter ended September 30, 2014 are not complete and it believes these financial statements will not become available prior to the effective date of the Registration Statement; however, the Company confirms that if such financial statements become available prior to the effective date of the Registration Statement, it will include them in the filing.

November 5, 2014

Page 2

We hope that the foregoing has been responsive to the Staff’s comments and look forward to resolving any outstanding issues as quickly as possible. Please do not hesitate to contact me at (202) 637-1028 or my colleague, Jason M. Licht, at (202) 637-2258 with any questions or further comments you may have regarding this filing or if you wish to discuss the above.

Enclosures

cc: (via email)

Charles W. Shaver of Axalta Coating Systems Ltd.

Robert W. Bryant of Axalta Coating Systems Ltd.

Michael F. Finn of Axalta Coating Systems Ltd.

Kamyar Daneshvar

Jeff Gordon

Jeanne Baker

Jason Licht of Latham & Watkins LLP