September 3, 2024

Thomas Fahnemann
Chief Executive Officer
Glatfelter Corp
4350 Congress Street, Suite 600
Charlotte, NC 28209

       Re: Glatfelter Corp
           Registration Statement on Form S-4
           Filed on August 23, 2024
           File No. 333-281733
Dear Thomas Fahnemann:

       We have reviewed your registration statement and have the following
comment(s).

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies to your facts
and circumstances
or do not believe an amendment is appropriate, please tell us why in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments.

Form S-4 filed August 23, 2024
Material U.S. Federal Income Tax Consequences, page 215

1.     We note you have included a short-form tax opinion as Exhibit 8.1 to the
registration
       statement. Please revise this section to state clearly that the
disclosure is the opinion of
       named counsel, and to ensure that the disclosure clearly identifies and
articulates the
       opinion being rendered with respect to each material tax consequence
being opined
       upon. Refer to Sections III.B and III.C of Staff Legal Bulletin 19 for
guidance. Without
       limitation, address the following:

              Revise disclosures on pages 216 and 217 that appear to
inappropriately condition the
            opinion: "Provided Berry receives the IRS Ruling and the Tax
Opinion, the Spinco
            Distribution, so qualifies as a tax-free distribution, and the IRS
Ruling and Tax
            Opinion continue to be valid, and in full force and effect" and
"Provided that Berry
            receives the Tax Opinion, the Merger so qualifies as a
'reorganization,' and the Tax
            Opinion continues to be valid, and in full force and effect."
 September 3, 2024
Page 2


                Revise disclosure on page 218 that assumes the reverse stock
split will not be
              integrated, and effectively describes the related tax
consequences hypothetically, to
              fully discuss the expected tax treatment and consequences. If
this opinion is subject to
              uncertainty, counsel may issue a "should" or "more likely than
not" opinion, disclose
              why it cannot give a "will" opinion, describe the degree of
uncertainty in the opinion,
              and provide relevant risk factor disclosure.
Exhibits

2.     Please revise the tax opinion filed as Exhibit 8.1 to address the
following:

                The assumptions in paragraphs (b)-(d) appear to inappropriately
refer to the
              registration statement in contractual terms. Counsel may assume
that the registration
              statement has been declared effective pursuant to the Securities
Act. Refer to Section
              II.B.3.a of Staff Legal Bulletin 19.

                The assumptions in paragraphs (c) and (d) appear overly broad.
Refer to
              Sections II.B.3.a and III.C.3 of Staff Legal Bulletin 19 for
guidance.

                The statement, "no opinion should be inferred as to the tax
consequences, whether
              federal, state, local or foreign, of any transactions related to
the Statements," appears
              inconsistent with your opinion "as to the material United States
federal income tax
              consequences of the Spinco Distribution . . . and the Merger."
General

3.     Please include a form of proxy card marked as    preliminary    in your
next amendment.
       Note that this should be filed as an appendix rather than an as exhibit.
Refer to Note to
       paragraph (a)(3) of Exchange Act Rule 14a-4.
 September 3, 2024
Page 3

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Charles Eastman at 202-551-3794 or Martin James at
202-551-3671 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Bradley Ecker at 202-551-4985 or Jennifer Angelini at 202-551-3047 with
any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing