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                              May 13, 2021

       Jean-Michel Ribi  ras
       Chief Executive Officer
       Sylvamo Corporation
       6400 Poplar Avenue
       Memphis, TN 38197

                                                        Re: Sylvamo Corporation
                                                            Draft Registration
Statement on Form 10
                                                            Submitted April 16,
2021
                                                            CIK No. 0001856485

       Dear Mr. Ribi  ras:

              We have reviewed your 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.

       Draft Registration Statement on Form 10

       Business Segment Results, page 81

   1.                                                   We note you disclose
Net Sales and Operating Profit (Loss) for each of your three
                                                        operating segments;
however, it is not clear to us how the amounts disclosed and
                                                        discussed in the
related narrative disclosures correlate to changes in the segment financial
                                                        measures you present.
Please revise your narrative disclosures to ensure you adequately
                                                        quantify and discuss
the factors that impacted the segment financial measures you present
                                                        during each period.
 Jean-Michel Ribi  ras
FirstName  LastNameJean-Michel Ribi  ras
Sylvamo Corporation
Comapany
May        NameSylvamo Corporation
     13, 2021
May 13,
Page 2 2021 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
2019 Compared to 2018 , page 81

2.       We note your discussion of net sales and income taxes for the periods.
Please expand the
         discussion of your consolidated results to provide a more
comprehensive and quantified
         discussion and analysis of the factors that impacted other line items
such as, but not
         limited to, selling and administrative expenses and distribution
expenses, as applicable.
Registration Rights Agreements, page 84

3.       Please disclose whether there are any maximum cash penalties under the
registration
         rights agreement, if applicable. Please also disclose any additional
penalties resulting from
         delays in registering your common stock. Please ensure any disclosures
required by ASC
         825-20-50-1 are provided.
Business   Our Raw Materials, page 110

4.       We note Sylvamo has long-term harvesting rights on 865,000 acres of
government-owned
         forestland in Russia, that yield 2.3 million tons of wood fiber used
as raw material in its
         mill. Please consider whether the nature and duration of these
harvesting rights should be
         described in light of the requirements of Item 101(c)(1)(iii) and/or
(iv) of Regulation S-K.
Directors and Executive Officers, page 119

5.       We note that only one director is currently identified (Chairman
Jean-Michel Ribi  ras)
         and that the Company states, "We are in the process of identifying
independent directors
         to serve on our board of directors at or following the time of the
distribution." Please
         advise as to the timeframe within which the Company intends to
determine the size and
         composition of the Board of Directors. If the Information Statement
will not be amended
         prior to effectiveness to include the requisite information for
directors and nominees,
         please consider revising to indicate when the director nomination
process will be
         completed and the means by such information will be provided to
shareholders. In
         addition, please specify the period, if any, during which Mr. Ribi
ras has served as a
         director of Sylvamo as required by Item 401(a) of Regulation S-K.
Executive Compensation, page 123

6.       We note the Company has not provided historical compensation
information pursuant to
         Item 402(a) and Item 407(e)(4) of Regulation S-K. Please address the
absence of this
         disclosure in light of the guidance contained in Regulation S-K
Compliance and
         Disclosure Interpretation 217.01.
Security Ownership of Certain Beneficial Owners and Management, page 124

7.       We note the table in this section is based on each person   s
beneficial ownership of
 Jean-Michel Ribi  ras
Sylvamo Corporation
May 13, 2021
Page 3
      International Paper common stock on the record date. In light of recent
13G and 13G/A
      filings in respect of International Paper's shares, please revise the
table as appropriate to
      include non-management beneficial owners, including their addresses as
specified by Item
      403(a) of Regulation S-K.
Financial Statements
General, page F-1

8.    Please note the updating requirements of Rule 3-12 of Regulation S-X.
Note 9 Income Taxes, page F-24

9.    We note your disclosures on page F-27 related to the Brazilian Federal
Revenue
      Service. Please clarify the amount of the surety bond provided by
International Paper that
      you may be required to replace.
       You may contact Anne Mcconnell at 202-551-3709 or Ernest Greene at
202-551-3733 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jennifer Angelini at 202-551-3047 or Jay Ingram at 202-551-3397 with
any other
questions.



                                                            Sincerely,
FirstName LastNameJean-Michel Ribi  ras
                                                            Division of
Corporation Finance
Comapany NameSylvamo Corporation
                                                            Office of
Manufacturing
May 13, 2021 Page 3
cc:       Eric T. Juergens
FirstName LastName