UNITED STATES
                                 SECURITIES AND EXCHANGE COMMISSION
                                              WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                                November 29,
2018

  By E-Mail

  Peter D. Fetzer, Esq.
  Foley & Lardner LLP
  777 East Wisconsin Avenue
  Milwaukee, WI 53202-5306

          Re:     Ashland Global Holdings Inc.
                  Soliciting Materials filed pursuant to Rule 14a-12 by 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
                  Filed on November 28, 2018
                  File No. 333-211719

  Dear Mr. Fetzer:

        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 this letter by amending your filing, by providing
the requested
  information, or by advising us when you will provide the requested response.
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 any amendment to your filing and the information you
provide in
  response to these comments, we may have additional comments.

  Soliciting Materials

  1.      You state on slide 5 of your presentation that Ashland is "worth well
in excess of $125+"
          and that it is "[p]otentially worth substantially more." The
inclusion of valuations in
          soliciting materials is only appropriate and consonant with Rule
14a-9 when made in
          good faith and on a reasonable basis and where accompanied by
disclosure which
          facilities shareholders' understanding of the basis for and the
limitations on the projected
          realizable values. See Exchange Act Release No. 16833 (May 23, 1980).
Please provide
          us with your analysis supporting your valuation of the company and
confirm that in
          future filings in which you provide a valuation you will include a
similar analysis. In
          addition, supplementally explain why your valuation is not so
qualified and subject to
          such material limitations and qualifications as to make inclusion of
the "$125+" figure
          and the next bullet point unreasonable.
 Peter D. Fetzer, Esq.
Foley & Lardner LLP
November 29, 2018
Page 2


        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff

       Please direct any questions to me at (202) 551-3619.

                                                            Sincerely,

                                                            /s/ Daniel F.
Duchovny
                                                            Daniel F. Duchovny
                                                            Special Counsel
                                                            Office of Mergers
and Acquisitions