KAR HOLDINGS, INC.
13085 HAMILTON CROSSING BLVD.
CARMEL, IN 46032
July 22, 2009
BY EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Catherine Brown, Esq.
| Re: | KAR Holdings, Inc. |
| Form S-1 Registration Statement and Post-Effective Amendment |
| No. 2 to Form S-1 Registration Statement (File No. 333-158666) |
Ladies and Gentlemen:
KAR Holdings, Inc. (the “Company”) hereby confirms that the Company’s independent registered public accounting firm, KPMG LLP, does not object to the Form S-1 Registration Statement and Post-Effective Amendment No. 2 to Form S-1 Registration Statement (File No. 333-158666) (the “Registration Statement”), originally filed by the Company on April 21, 2009 and amended on June 17, 2009 and July 2, 2009, being declared effective without a new auditor consent. The Company has submitted a request, dated the date hereof, to the Securities and Exchange Commission that the effective date of the Registration Statement be accelerated to 4:00 p.m. Eastern Daylight Time on July 23, 2009 or as soon as practicable thereafter.
Very truly yours, | ||
| KAR HOLDINGS, INC. | ||
| By: | /s/ Rebecca C. Polak | |
| Name: Rebecca C. Polak | ||
| Title: Executive Vice President, | ||
| General Counsel and Secretary | ||
| cc: | Mark Shaffer, KPMG LLP |
| 111 Monument Circle, Suite 1500 |
| Indianapolis, IN 46204 |