[URI Letterhead]
October 30, 2009
Ms. Pamela A. Long
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re: | United Rentals (North America), Inc. — |
| Registration Statement on Form S-4 (File Number 333-160885) |
Dear Ms. Long:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, United Rentals (North America), Inc. and its parent and subsidiary guarantor co-registrants (the “Company”) hereby respectfully requests acceleration of effectiveness of the above-captioned registration statement on Form S-4 (File no. 333-160885) (the “Registration Statement”) to Monday, November 2, 2009, at 4:00 p.m. Eastern Time, or as soon thereafter as practicable.
In requesting acceleration of effectiveness of the Registration Statement, the Company acknowledges that should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact Andrew D. Soussloff of Sullivan & Cromwell LLP at (212) 558-3681 or me at 203-622-3131 with any questions you may have. In addition, please notify Mr. Soussloff when this request for acceleration has been granted.
| Very truly yours, |
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| /s/ Jonathan M. Gottsegen |
| Jonathan M. Gottsegen |
| Senior Vice President, General Counsel and Corporate Secretary |
cc: | Ms. Chambre Malone |
| Mr. Dietrich King |
| (U.S. Securities and Exchange Commission) |
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| Andrew D. Soussloff |
| (Sullivan & Cromwell LLP) |