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                             October 21, 2022

       Timothy R. Kraus
       Senior Vice President and Chief Financial Officer
       Dana Incorporated
       3939 Technology Drive
       Maumee, Ohio 43537

                                                        Re: Dana Incorporated
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Response Dated
October 13, 2022
                                                            File No. 001-01063

       Dear Timothy R. Kraus:

              We have reviewed your October 13, 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
       September 29, 2022 letter.

       Response Dated October 13, 2022

       Risk Factors, page 7

   1.                                                   We note your response
to prior comment one and reissue it as your response does not
                                                        appear to have
addressed transition risks related to climate change. Please tell us how you
                                                        considered providing
disclosure addressing the transition risks related to climate change
                                                        identified in our
previously issued comments, including with regard to your assessment of
                                                        their effect on your
business, financial condition, and results of operations.
 Timothy R. Kraus
FirstName LastNameTimothy R. Kraus
Dana Incorporated
Comapany
October 21,NameDana
            2022     Incorporated
October
Page 2 21, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
15

2.       We note your response to prior comment two quantifies expenditures for
climate-related
         projects for 2021. Please provide quantification for each of the other
periods covered by
         your Form 10-K, or affirmatively state if there were no such
expenditures. Additionally
         tell us if amounts are expected to increase in future periods.
3.       We note your response, yet reissue prior comment three as it does not
appear that each of
         the items identified in our original comment (i.e., comment five of
our letter dated August
         26, 2022) is addressed in your response. Please provide us with your
analysis of the
         indirect consequences of climate-related regulations or business
trends for each of the
         items noted in our prior comment. Include information explaining how
the disclosed risks
         related to such consequences specifically address developments
regarding climate change
         or tell us how you concluded on the materiality of the items for which
disclosure was not
         deemed necessary.
       Please contact Erin Donahue at 202-551-6063 or Jennifer Angelini at
202-551-3047 with
any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Manufacturing