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                             May 3, 2022

       Peter D. Fetzer
       Foley & Larder LLP
       777 East Wisconsin Avenue
       Suite 3800
       Milwaukee, WI 53202

                                                        Re: American Vanguard
Corp.
                                                            Preliminary Proxy
Statement filed by Cruiser Capital Advisors, LLC, Keith M.
                                                            Rosenbloom, Cruiser
Capital Master Fund LP, Metamorphosis VI LLC,
                                                            Patrick E.
Gottschalk, and Mark R. Bassett
                                                            Filed April 27,
2022
                                                            File No. 001-13795

       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 these comments 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.

       Preliminary Proxy Statement

       What do the Cruiser Director Nominees Hope to Achieve?, page 3

   1.                                                   Please clarify whether
your nominees have a plan to achieve their stated goals.
   2.                                                   Please revise your
proxy statement to provide additional information on the amount of
                                                        board fees referenced
at the top of page 4.
       Background of the Solicitation, page 6

   3.                                                   Please revise the
disclosure in this section to describe the events surrounding your
                                                        apparent decision to
nominate only three candidates instead of the four indicated in your
                                                        March 7, 2022 notice to
the company.
 Peter D. Fetzer
FirstName  LastNamePeter
777 East Wisconsin  AvenueD. Fetzer
Comapany
May  3, 2022Name777 East Wisconsin Avenue
May 3,
Page  2 2022 Page 2
FirstName LastName
Proposal 1. Election of Directors, page 9

4.       Please disclose the names of the companies "Mr. Rosenbloom has helped
...add highly
         qualified members to their Board rooms, seeking to improve stockholder
value at those
         companies."
5.       With a view toward revised disclosure, please tell us why, in light of
the plurality voting
         standard to be used for the election of directors, "stockholders will
not be able to abstain
         from voting in the election of directors."
Proposal 3. Approval of the 2022 Stock Incentive Plan, page 12

6.       We note that you "...have been disappointed with AVD   s ....(4) the
dilutive effect of its
         incentive stock plan..." while you also recommend a vote for the
approval of the 2022
         stock incentive plan. Please address this apparent contradiction.
Form of Proxy Card, page A-4

7.       Please revise your proxy card to indicate how signed but unmarked
proxy cards will be
         voted.
8.       We note the proposal number 5 included in your form of proxy card. We
also note that the
         company has not included an adjournment proposal in its proxy
materials. Please advise
         or revise.
        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 Daniel Duchovny at 202-551-3619.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Mergers & Acquisitions