Element Solutions Inc — Regulatory Filings 2016

Jul 21, 2016

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1450 Centrepark Boulevard, Suite 210

West Palm Beach, FL 33401

(561) 207-9600

July 21, 2016

VIA EDGAR SUBMISSION Mr. John Cash Accounting Branch Chief Office of Manufacturing and Construction United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549

RE:
Form 10-K for the Year Ended December 31, 2015
Filed March 11, 2016
File No. 1-36272

Dear Mr. Cash:

We are writing in response to the comments we received from the staff (the " Staff ") of the Securities and Exchange Commission (the " Commission ") by letter dated July 19, 2016 (the " Comment Letter ") regarding the above-referenced filing of Platform Specialty Products Corporation (" Platform " or the " Company "). For ease of reference in this letter, the headings and numbered paragraphs correspond to the headings and paragraph numbers contained in the Comment Letter. To facilitate your review, we have also reproduced below the text of the Staff's comments in italics directly above the Company's responses.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of Operations

1.
In response to the Staff's comment, in future filings, to the extent there are significant foreign currency translation adjustments in the periods presented, the Company will expand its MD&A to discuss any changes in foreign currency rates, if applicable, or other factors that resulted in such significant foreign currency translation adjustments.

2.
In response to the Staff's comment, in future filings, if material, the Company will include a segment discussion and analysis in its MD&A, and when such segment discussion and analysis is included, will also include segment-level tables for the financial line items for which segment-level discussion and analysis is provided.

3.
In response to the Staff's comment, in future filings, the Company will discuss and analyze material changes in effective tax rates for all periods presented. This analysis will include a discussion of the underlying factors that contributed to such material changes in the individual reconciling items on its effective tax rates as required by Item 303(a) of Regulation S-K.

Liquidity and Capital Resources

Contractual Obligations and Commitments, Page 56

4.

In response to the Staff's comment, in future filings, if the Company is otherwise required to include the contractual obligations and commitments table, the Company will include a footnote to the table which affirmatively states that the settlement of the Series B Convertible Preferred Stock obligation is not included in the table and provides an estimated amount of the settlement based on the current stock price (which estimated amount has been historically disclosed in a paragraph within the Contractual Obligations and Commitments section).

Consolidated Financial Statements and Footnotes

Consolidated Balance Sheets, Page F-3

5.
The Company, after considering the guidance in ASC 480-10-25-4, determined that the Series B Convertible Preferred Stock is not mandatorily redeemable but should, however, be classified as mezzanine equity in accordance with ASC 480-10-S99 because the instrument is redeemable based upon an event that is outside of the Company's control, i.e., the stock price of Platform's common stock.
The Series B Convertible Preferred Stock is convertible into the Company's common stock and that conversion right was considered by the Company to be substantive. In addition, the Series B Convertible Preferred Stock is contingently redeemable either upon a triggering event as defined in the related share purchase agreement or upon maturity; provided it has not already been converted by the holder. ASC 480-10-55-11 clarifies that an otherwise mandatorily redeemable instrument with a substantive option to convert is not mandatorily redeemable until the option lapses.

Note 5 - Goodwill and Intangible Assets, Page F-22

6.
In response to the Staff's comment, in future filings, the Company will expand its disclosure to discuss any potential events or circumstances that could have a negative effect on the estimated fair value of the Company's Agro business.

The Company hereby acknowledges that:

• the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

• the Company many not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

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If you or any other members of the Staff have any questions with respect to the foregoing, please contact me at (561) 207-9635 or John E. Capps at (561) 207-9604.

Very truly yours,
/s/ Sanjiv Khattri
Sanjiv Khattri
Chief Financial Officer

cc: John E. Capps, Platform Specialty Products Corporation

Sisi Cheng, Staff Accountant, Securities and Exchange Commission