United States securities and exchange commission logo March 16, 2023 Mark Humphrey Chief Financial Officer Herc Holdings Inc. 27500 Riverview Center Blvd. Bonita Springs, FL 34134 Re: Herc Holdings Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 14, 2023 File No. 001-33139 Dear Mark Humphrey: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 8. Financial Statements and Supplementary Data Note 11- Debt Accounts Receivable Securitization Facility, page 59 1. You state that the AR Facility is excluded from current maturities of long-term debt as you have the intent and ability to consummate refinancing and extend the term of the agreement. Please provide us with your analysis supporting your accounting. Refer to ASC 470-10-45-14. Mark Humphrey Herc Holdings Inc. March 16, 2023 Page 2 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. You may contact Scott Stringer at 202-551-3272 or Joel Parker at 202-551-3651 with any other questions. FirstName LastNameMark Humphrey Sincerely, Comapany NameHerc Holdings Inc. Division of Corporation Finance March 16, 2023 Page 2 Office of Trade & Services FirstName LastName