August 19, 2019

Robert R. Krakowiak
Executive Vice President, Chief Financial Officer and Treasurer
Stoneridge Inc.
39675 MacKenzie Drive, Suite 400,
Novi, Michigan 48377

       Re: Stoneridge Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed February 28, 2019
           File No. 001-13337

Dear Mr. Krakowiak:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018.

Item 1. Business
Backlog, page 4

1.    Please tell us how your disclosure herein regarding backlog complies with
the disclosure
      of backlog pursuant to Item 101(c)(1)(viii) of Regulation S-K.
Additionally, please clarify
      for us if the terms "cumulative remaining sales", "estimated net sales"
and "expected net
      sales" represent the same measure and how they relate to backlog pursuant
to the noted
      guidance.
MD&A
Liquidity and Capital Resources
Summary of Future Cash Flows, page 30

2.    It appears the cash interest payments on your credit facility and debt
obligations may
      represent a material contractual obligation. Because this table is aimed
at increasing
 Robert R. Krakowiak
Stoneridge Inc.
August 19, 2019
Page 2
         transparency of cash flow, we believe these payments should be
included in the table or
         disclosed in the footnotes using the same time frames stipulated in
the table. Please also
         disclose any assumptions you made to derive these amounts. If you
choose not to include
         these payments, a footnote to the table should clearly identify the
excluded item and
         provide any additional information that is material to an
understanding of your cash
         requirements. Refer to Item 303(a)(5) of Regulation S-K and footnote
46 to SEC Release
         No. 33-8350.

         We also note your disclosure that in December 2018, you entered into
an agreement to
         make a $10 million investment in a fund managed by Autotech Ventures.
Please tell us
         what consideration you gave to including this commitment in the table.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.



       You may contact Aamira Chaudhry at 202-551-3389 or Lyn Shenk at
202-551-3380 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameRobert R. Krakowiak                         Sincerely,
Comapany NameStoneridge Inc.
                                                              Division of
Corporation Finance
August 19, 2019 Page 2                                        Office of
Transportation and Leisure
FirstName LastName