Wyndham Worldwide Corporation
7 Sylvan Way
Parsippany, New Jersey 07054
June 15, 2006
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-4561
| Attn: | Michael McTiernan, Esq. |
| Special Counsel |
| RE: | Wyndham Worldwide Corporation |
Registration Statement on Form 10
Commission File No. 001-32876
Dear Mr. McTiernan:
In connection with the above referenced Registration Statement on Form 10, as amended (the “Filing”), of Wyndham Worldwide Corporation (the “Company”), the undersigned hereby acknowledges on behalf of the Company:
| (i) | the Company is responsible for the adequacy and accuracy of the disclosure in the Filing; |
| (ii) | staff comments or changes to disclosure in response to staff comments do not foreclose the Securities and Exchange Commission (the “Commission”) from taking any action with respect to the Filing; and |
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| (iii) | the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
| Very truly yours, | ||||
| WYNDHAM WORLDWIDE CORPORATION | ||||
| By: | /s/ Virginia M. Wilson | |||
| Name: |
Virginia M. Wilson | |||
| Title: |
Executive Vice President and Chief Financial Officer | |||
| cc: | Geoffrey Ossias |
| Matthew Maulbeck |
| Josh Forgione |
| Eric J. Bock |
| Scott G. McLester |
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