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                            June 21, 2022

       Toni Y. Hickey
       Chief Legal Officer and Corporate Secretary
       FILT Red, Inc.
       26 Century Boulevard
       Nashville, Tennessee 37214

                                                        Re: FILT Red, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Filed June 7, 2022
                                                            CIK No. 0001921963

       Dear Ms. Hickey:

             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.

       Amendment No. 1 to the Draft Registration Statement on Form S-1
submitted June 7, 2022

       Unaudited Pro Forma Condensed Combined Financial Information, page 52

   1.                                                   On page 53, you express
your expectation    to incur recurring costs associated with being a
                                                        standalone public
company.    Please revise your disclosure to distinguish between the
                                                        bulleted items that are
and are not covered by your transition services agreement. For
                                                        those items that are
not covered by your transition services agreement, more fully explain
                                                        to us the basis for
your conclusion that pro forma effect is not required to be given. In
                                                        your explanation,
please clarify, but do not limit your explanation to, whether any such
                                                        amounts will be or are
expected to be paid to Cummins Inc.; whether new employees will
                                                        be in place at the
latest date of the transactions for which you give pro forma effect;
                                                        insight into the need
for and timing of incremental compensation to existing employees
 Toni Y. Hickey
FILT Red, Inc.
June 21, 2022
Page 2
      and whether any such compensation will relate to service, performance or
market
      conditions achieved prior to the separation and offering; and whether
agreements for the
      items not covered by your transition services agreement will be in place
or are in
      negotiations, and, if applicable, the status of such negotiations. If the
items not covered
      by your transition services agreement represent dis-synergies, consider
identifying them as
      such in your disclosure and tell us whether you considered the option to
present them as
      management   s adjustments. In this regard, it is not clear whether your
"factually
      supportable" reference is meant to explain why you have not opted to
present
      management   s adjustments. Lastly, revise your disclosure to clarify
what the last
      bullet    the type and level of other costs expected to be incurred
means.
2.    We note on page 53 that you refer to    one-time expenses associated with
becoming a
      standalone public company.    As a follow-up to the previous comment,
please analyze for
      us and consider the need for revised disclosure to clarify whether each
item listed is a
      transaction for which pro forma effect is required by Rule 11-01 of
Regulation S-X and
      the reasons supporting your conclusions. In your reply, explain the
relevance to your
      analysis of your references to "factually supportable" and "ongoing
effect."
3.    We note that pages 52 and 53 refer to more than one transition services
agreement, pro
      forma Note 1(a) refers to a single transition services agreement, and
page 58 refers to a
      separation agreement that includes a number of other agreements, only one
of which is
      referred to as a transition services agreement. Please revise your pro
forma disclosures to
      specify which page 58 agreements are and are not given effect in the pro
forma financial
      statements. For any page 58 agreement that is not given pro forma effect,
please explain
      the reasons for your determination.
Note 15: Relationship with Parent and Related Parties, page F-27

4.    We note your response to comment 17. Pursuant to Rule 4-08(k)(1) of
Regulation S-X,
      please disclose the amount of related party cost of sales on the face of
your statements of
      income. Also revise your results of operations discussion in MD&A to
separately discuss
      third-party and related party sales, cost of sales, and gross margins.
       You may contact Jeff Gordon at 202-551-3866 or Andrew Blume at
202-551-3254 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Erin Donahue at 202-551-6063 or Geoffrey Kruczek at 202-551-3641 with
any other
questions.



                                                            Sincerely,
FirstName LastNameToni Y. Hickey
                                                            Division of
Corporation Finance
Comapany NameFILT Red, Inc.
                                                            Office of
Manufacturing
June 21, 2022 Page 2
cc:       Mark L. Mandel
FirstName LastName