September 26, 2019

Daniel Hughes
Chief Executive Officer
Hilton Domestic Operating Co Inc.
7930 Jones Branch Drive
Suite 1100
McLean, VA 22102

       Re: Hilton Domestic Operating Co Inc.
           Form S-4
           Filed September 20, 2019
           File No. 333-233870

Dear Mr. Hughes:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Stacie Gorman at 202-551-3585 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate and
                                                            Commodities
cc:    Joshua Ford Bonnie, Esq.