TEXT-EXTRACT 2 filename2.txt May 16, 2019 James Hunter, IV Executive Vice President and General Counsel Marriott Ownership Resorts, Inc. 6649 Westwood Blvd. Orlando, FL 32821 Re: Marriott Ownership Resorts, Inc. Registration Statement on Form S-4 Filed May 8, 2019 File No. 333-231300 Dear Mr. Hunter: 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 Jennifer Gowetski at 202-551-3401 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate and Commodities