HILTON GRAND VACATIONS BORROWER LLC
HILTON GRAND VACATIONS BORROWER INC.
6355 MetroWest Boulevard, Suite 180
Orlando, Florida 32835
December 6, 2017
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549-3010
Attention: Kasey Robinson
| RE: | Hilton Grand Vacations Borrower LLC |
Hilton Grand Vacations Borrower Inc.
Amendment No. 1 to Registration Statement on FormS-4
FileNo. 333-221194
Dear Ms. Robinson:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Hilton Grand Vacations Borrower LLC, Hilton Grand Vacations Borrower Inc., and the additional registrants listed in the above-captioned registration statement hereby request that the effective date of the above-captioned registration statement be accelerated so that it may become effective at 4:00 p.m., Washington, D.C. time, on December 8, 2017, or as soon thereafter as practicable.
We request that we be notified of such effectiveness by telephone call to Alexander J. Park at(202) 857-4418 of Womble Bond Dickinson (US) LLP.
| Very truly yours, | ||
| HILTON GRAND VACATIONS BORROWER LLC | ||
| By: | /s/ Charles R. Corbin | |
| Name: | Charles R. Corbin | |
| Title: | Executive Vice President and Secretary | |
| HILTON GRAND VACATIONS BORROWER INC. | ||
| By: | /s/ Charles R. Corbin | |
| Name: | Charles R. Corbin | |
| Title: | Executive Vice President and Secretary | |
| cc: | Alexander J. Park, Esq., |
Womble Bond Dickinson (US) LLP
