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                             June 2, 2022

       Jennifer F. Scanlon
       President and Chief Executive Officer
       UL Inc.
       333 Pfingsten Road
       Northbrook, Illinois 60062

                                                        Re: UL Inc.
                                                            Amendment No. 3 to
Draft Registration Statement on Form S-1
                                                            Submitted May 18,
2022
                                                            CIK No. 0001901440

       Dear Ms. Scanlon:

             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 No. 3 to Draft Registration Statement on Form S-1 Submitted
May 18, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Key Operating Metrics and Non-GAAP Financial Measures, page 82

   1.                                                   We note your discussion
and presentation of key operating metrics and Non-GAAP
                                                        financial measures
precedes your discussion and presentation of operations on a GAAP
                                                        basis. Please tell us
your consideration of Item 10(e)(1)(i)(A) of Regulation S-K and
                                                        Question 102.10 of the
Compliance and Disclosure Interpretations on Non-GAAP
                                                        Financial Measures.
       COVID-19 Impact, page 86

   2.                                                   We note your disclosure
that you have experienced supply chain disruptions in the first
 Jennifer F. Scanlon
UL Inc.
June 2, 2022
Page 2
      quarter of 2022. Please discuss whether supply chain disruptions
materially affect your
      outlook or business goals, and revise to discuss known trends or
uncertainties resulting
      from mitigation efforts undertaken, if any. Explain whether any
mitigation efforts
      introduce new material risks, including those related to service quality
or reliability.
Results of Operations, page 88

3.    You disclose that "Revenue in the first quarter of 2021 was also impacted
by a
      ransomware attack, which resulted in disruption to our systems and our
ability to service
      our customers, primarily in the Consumer segment." Please quantify the
impact of the
      ransomware attack on your revenue and operations. Make conforming changes
to your
      risk factors, as appropriate.
       You may contact Keira Nakada at 202-551-3659 or Theresa Brillant at
202-551-3307 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Taylor Beech at 202-551-4515 or Katherine Bagley at 202-551-2545 with
any other
questions.



                                                           Sincerely,
FirstName LastNameJennifer F. Scanlon
                                                           Division of
Corporation Finance
Comapany NameUL Inc.
                                                           Office of Trade &
Services
June 2, 2022 Page 2
cc:       Cathy A. Birkeland, Esq.
FirstName LastName