TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo December 4, 2023 William E. Grace Executive Vice President and Chief Financial Officer United Rentals, Inc. 100 First Stamford Place, Suite 700 Stamford, CT 06902 Re: United Rentals, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Form 8-K Furnished January 25, 2023 File No. 001-14387 Dear William E. Grace: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 8-K Furnished January 25, 2023 Exhibit 99.1 Summary of Fourth Quarter 2022 Financial Results Used Equipment Sales 1. You disclose what appears to be a non-GAAP financial measure, used equipment adjusted gross margin. Please revise to reconcile this measure to the most directly comparable GAAP measure, either in a table or by quantifying the adjustment in the related footnote. Refer to Item 10(e)(1)(i)(B) of Regulation S-K. In closing, 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. William E. Grace United Rentals, Inc. December 4, 2023 Page 2 Please contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any questions. FirstName LastNameWilliam E. Grace Sincerely, Comapany NameUnited Rentals, Inc. Division of Corporation Finance December 4, 2023 Page 2 Office of Trade & Services FirstName LastName