January 8, 2020

Geoff Wild
Chief Executive Officer
Atotech Ltd
William Street, West Bromwich
West Midlands, B70 0BG
United Kingdom

       Re: Atotech Ltd
           Amendment No. 4 to
           Draft Registration Statement on Form F-1
           Submitted December 30, 2019
           CIK No. 0001762459

Dear Mr. Wild:

      We have reviewed your amended draft registration statement and have the
following
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
comments.

Draft Registration Statement on Form F-1

Summary Historical and Pro Forma Financial Information, page 21

1.     Given the reclassifications that you made to your Consolidated Balance
Sheet as of
       September 30, 2019, please revise the Non-current assets, Total assets,
and Total
       liabilities line items in the balance sheet data section of your table
to agree with the
       corresponding line items on your Consolidated Balance Sheet. This
comment also applies
       to the Selected Historical Financial Information on page 68.
 Geoff Wild
FirstName LastNameGeoff Wild
Atotech Ltd
Comapany2020
January 8, NameAtotech Ltd
January 8, 2020 Page 2
Page 2
FirstName LastName
Management
Compensation, page 130

2.       Please revise your disclosure in this section to include your most
recently completed fiscal
         year. Please refer to Section I.6.B. of Form 20-F.
       You may contact Dale Welcome at 202-551-3865 or John Cash at
202-551-3768 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Erin Purnell at 202-551-3454 or Jay Ingram at 202-551-3397 with any
other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Manufacturing
cc:      Patrick H. Shannon