September 16, 2019

John A. Haudrich
Chief Financial Officer
OWENS ILLINOIS INC /DE/
One Michael Owens Way
Perrysburg, Ohio 43551

       Re: OWENS ILLINOIS INC /DE/
           Form 10-K For the Year Ended December 31, 2018
           Filed February 14, 2019
           File No. 001-09576

Dear Mr. Haudrich:

        We have reviewed your August 21, 2019 response to our comment letter
and have the
following comment. In our comment, we ask you to provide us with information so
we may
better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
July 24, 2019 letter.

Form 10-K for the year ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
26

1.    We appreciate the information you provided in your response to prior
comment 1 in your
      letter dated August 21, 2019. Please more fully address the following:
        In regard to our request to disclose how you determined the amount of
the additional
          asbestos-related charge you recorded, we note that you develop
information to assist
          you in estimating the total number of future Asbestos Claims likely
to be asserted
          against the Company and use this estimate, along with an estimation
of disposition
          costs and related legal costs, as inputs to develop your best
estimate of the total
          probable liability. Please tell us what additional information you
can disclose to help
          investors understand the specific changes in your assumptions,
including the
 John A. Haudrich
OWENS ILLINOIS INC /DE/
September 16, 2019
Page 2
             magnitude of the changes, that impacted your asbestos-related
liability, such as the
             percentage increase in the number of claims likely to be asserted
and the percentage
             increase in disposition costs and related legal costs; and
             In regard to our request to disclose updated claims activity
roll-forwards in your
             Form 10-Qs, we note that you indicate a large volume of the
Company's claim
             dispositions have historically occurred in the fourth quarter of
each year. In light of
             the recent change in your claims strategy, we note that during the
six months ended
             June 30, 2019 your asbestos payments increased ~300% relative to
the comparable
             prior year period. Please tell us what additional information you
can disclose to help
             investors understand and assess your asbestos payments on a
quarterly basis, such as
             the number of claims disposed of during each period.
       You may contact SiSi Cheng at 202-551-5004 or Anne McConnell at
202-551-3709 if
you have any questions.



                                                               Sincerely,
FirstName LastNameJohn A. Haudrich
                                                               Division of
Corporation Finance
Comapany NameOWENS ILLINOIS INC /DE/
                                                               Office of
Manufacturing and
September 16, 2019 Page 2                                      Construction
FirstName LastName