[Goldman, Sachs & Co. Letterhead]
December 8, 2009
VIA EDGAR AND FACSIMILE
Securities and Exchange Commission
100 “F” Street, N.E.
Washington, D.C. 20549
| Re: | KAR Auction Services, Inc. |
Filed on Form S-1
Registration No. 333-161907
Ladies and Gentlemen:
In connection with the above-captioned Registration Statement, we wish to advise that between November 30, 2009 and the date hereof 11,469 copies of the Preliminary Prospectus dated November 30, 2009 were distributed as follows: 9,687 to 11 prospective underwriters; 1,663 to 1,663 institutional investors; 105 to 2 prospective dealers; 5 to 3 individuals; 9 to 3 rating agencies and 0 to 0 others.
We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934.
We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 3:30 p.m. on December 10, 2009 or as soon thereafter as practicable.
Very truly yours,
GOLDMAN, SACHS & CO.
CREDIT SUISSE SECURITIES (USA) LLC
J.P. MORGAN SECURITIES INC.
MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED
As Representatives of the Prospective Underwriters
| By: | /s/ Goldman, Sachs & Co. | |
| (Goldman, Sachs & Co.) |
