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                              October 13, 2021

       Bryant Kirkland
       Chief Financial Officer
       Douglas Elliman Inc.
       4400 Biscayne Boulevard
       Miami, FL 33137

                                                        Re: Douglas Elliman
Inc.
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form 10
                                                            Submitted September
30, 2021
                                                            CIK No. 0001878897

       Dear Mr. Kirkland:

               We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment #1 to Draft Registration Statement on Form S-1 filed September
30, 2021

       Our Company, page 2

   1.                                                   Further to our prior
comment 1, the presentation of information about your company
                                                        under the headings
"Real Estate Services" and "Real Estate Technology" and the
                                                        prominence of the
graphic on page 4 may suggest to investors that these are
                                                        separate,
revenue-generating lines of business or operations. Please revise to address
                                                        whether Real Estate
Technology is actually a separate revenue-generating line of business,
                                                        or is instead a
resource that is used in your real estate services business. As requested in
                                                        prior comment 1, please
also address the relative materiality of these two items to the
                                                        company's financial
position and operations by providing appropriate comparable
 Bryant Kirkland
Douglas Elliman Inc.
October 13, 2021
Page 2
      quantitative and narrative information. In this regard, we note
disclosure in the summary
      under "Real Estate Technology" that you have invested $6.3 million in
PropTech
      companies, but no disclosure similar to your statement in response to
comment 2 that as of
      June 30, 2021, the company had approximately $525 million in total
assets. We also note
      disclosure in MD&A that approximately 95% of revenues are attributable to
      commissions and other brokerage income, which we assume is included in
"Real Estate
      Services."
Real Estate Technology, page 4

2.    We note your response to our prior comment 1. On page 6, you state that
"Other than the
      funds in which New Valley Ventures invests as a limited partner, all of
these companies
      currently provide technology or services to Douglas Elliman, or Douglas
Elliman
      anticipates using such technology or services in the near future". Please
limit your
      disclosure and graphic to those companies whose technology and services
you currently
      use and those in which you are currently invested. If you wish to
disclose other companies
      with whom you anticipate obtaining technology and services from in the
future, describe
      the current status of any negotiations or arrangements you have with them
and clarify that
      there can be no assurance you will actually be able to obtain those
services or technology.
Exclusive Jurisdiction of Certain Actions, page 118

3.    We note your response to our prior comment 7, and disclosure on page 119
that United
      States federal district courts will be the exclusive forum for claims
arising under the
      Securities Act. Please revise your disclosure regarding your exclusive
forum provision to
      state that investors cannot waive compliance with the federal securities
laws and the rules
      and regulations thereunder. Additionally, if your exclusive forum
provision does not apply
      to actions arising under the Securities Act or Exchange Act, please
ensure that the
      exclusive forum provision in the governing documents states this clearly,
or tell us how
      you will inform investors in future filings that the provision does not
apply to any actions
      arising under the Securities Act or Exchange Act.
       You may contact Babette Cooper at 202-551-3396 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Patrick Costello at 202-551-8742 or Pam Long at 202-551-3765 with any
other
questions.



                                                            Sincerely,
FirstName LastNameBryant Kirkland
                                                            Division of
Corporation Finance
Comapany NameDouglas Elliman Inc.
                                                            Office of Real
Estate & Construction
October 13, 2021 Page 2
cc:       Robert Downes, Esq.
FirstName LastName