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United States securities and exchange commission logo





                           July 29, 2022

       Samuel L. Hillard
       Senior Vice President and Chief Financial Officer
       Glatfelter Corporation
       4350 Congress Street, Suite 600
       Charlotte, North Carolina 28209

                                                        Re: Glatfelter
Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Form 10-Q for the
Fiscal Quarter Ended March 31, 2022
                                                            File No. 001-03560

       Dear Mr. Hillard:

              We have reviewed your May 18, 2022 response to our comment letter
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. Unless we note otherwise, our references to prior comments are
to comments in our
       May 4, 2022 letter.

       Form 10-Q for the quarterly period ended March 31, 2022

       Part I - Item 2. Management's Discussion and Analysis of Financial
Condition and Results of
       Operations
       Results of Operations
       Overview, page 27

   1.                                                   We note your response
to prior comment 1, including the additional disclosures you
                                                        provided; however,
please more fully explain how you considered Question 102.11 of the
                                                        Division   s C&DI for
Non-GAAP Financial Measures in determining the income tax
                                                        effects of adjustments
related to your non-GAAP financial measure, Adjusted Earnings,
                                                        for FY 2021. Please
specifically address your consideration of the extent to which U.S.
                                                        deferred tax assets may
relate to expenses previously excluded from non-GAAP financial
                                                        measures.
 Samuel L. Hillard
FirstName   LastNameSamuel L. Hillard
Glatfelter Corporation
Comapany
July        NameGlatfelter Corporation
     29, 2022
July 29,
Page  2 2022 Page 2
FirstName LastName
2.       We note your non-GAAP financial measures, Adjusted Earnings and
Adjusted EBITDA,
         include adjustments for bad debt expense and inventory reserves that
you attribute to the
         conflict between Russia and Ukraine; however, these expenses appear to
be normal,
         recurring, operating expenses related to your business. Please explain
how you
         considered Question 100.01 of the Division   s C&DI for Non-GAAP
Financial Measures
         and why you believe excluding these expenses from non-GAAP performance
measures is
         appropriate.
Segment Financial Performance, page 29

3.       We note your disclosures that the conflict between Russia and Ukraine
and inflationary
         and supply chain issues have impacted your operating results during
the current interim
         period and it appears you expect these issues may continue to impact
your future
         results. Please enhance your disclosures to more fully address the
following:
             Quantify decreases in sales related to lower shipments to
customers in Russia and
             Ukraine;
             Disclose and discuss trends in costs related to energy, raw
materials and freight,
             including the percentage increases you experienced during each
period, whether costs
             are continuing to increase or stabilizing, and your expectations
regarding trends in
             your costs and the factors you believe may impact trends;
             Disclose and discuss the reasons why certain segments appear to
have the ability to
             pass through increased costs to customers and others do not;
             Disclose any material impact of import or export bans on products
or commodities,
             including energy from Russia, used in your business, or sold by
you, including the
             current and anticipated impact on your business, taking into
account the availability
             of materials, costs of needed materials, costs and risks
associated with transportation,
             and the impact on margins and customers; and
             Discuss any actions you have taken mitigate the impact of the
conflict between
             Russia and Ukraine and inflationary and supply chain issues on
your business.
4.       We note your disclosures regarding the impairment charges you recorded
during the
         current interim period primarily due to the conflict between Russia
and Ukraine. Please
         enhance your disclosures to more fully address the following:
             Disclose the remaining carrying values of any impaired assets, if
applicable;
             Explain the methods you used to develop fair value estimates and
the significant
             assumptions underlying the estimates, such as discounted cash flow
and discount rate
             assumptions;
             Explain to us why the apparent significant exposure of the Dresden
facility on sales
             into Russian and Ukrainian markets was not previously disclosed;
and
             Based on disclosures in your risk factor, more fully discuss the
number and carrying
             values of the other manufacturing sites in Europe that have been
adversely impacted,
             including those impacted or that may be impacted as a result of
the availability of
             natural gas, and explain the extent to which you believe
additional material asset
             impairments are reasonably possible.
 Samuel L. Hillard
Glatfelter Corporation
July 29, 2022
Page 3


Part II - Other Information - Item 1A. Risk Factors, page 36

5.       We note your risk factor discloses the heightened risk of potential
cyberattacks due to the
         conflict between Russia and Ukraine. Please revise your risk factor to
disclose if you
         have experienced any cyberattacks, explain how cyberattacks could
impact your business,
         and discuss any actions you have taken to mitigate the potential
risks.
        You may contact Andi Carpenter at 202-551-3645 or Anne McConnell at
202-551-3709
if you have questions regarding comments on the financial statements and
related matters.



FirstName LastNameSamuel L. Hillard                            Sincerely,
Comapany NameGlatfelter Corporation
                                                               Division of
Corporation Finance
July 29, 2022 Page 3                                           Office of
Manufacturing
FirstName LastName
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