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                              August 3, 2022

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

                                                        Re: UL Inc.
                                                            Amendment No. 4 to
Draft Registration Statement on Form S-1
                                                            Submitted July 19,
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. 4 to Draft Registration Statement on Form F-1 filed July
19, 2022

       Risk Factors
       An increase in interest rates would increase interest costs on our
Credit Facility . . ., page 60

   1.                                                   Please expand your
discussion of interest rates to specifically identify the impact of recent
                                                        rate increases on your
operations and how your business has been affected. For example,
                                                        describe whether your
borrowing costs have recently increased or are expected to increase
                                                        and your ability to
pass along your increased costs to your customers.
 Jennifer F. Scanlon
FirstName
UL Inc. LastNameJennifer F. Scanlon
Comapany
August      NameUL Inc.
        3, 2022
August
Page 2 3, 2022 Page 2
FirstName LastName
Management's Discussion & Analysis of Financial Condition and Results of
Operations, page 80

2.       We note your discussion of the potential impact of rising interest
rates on operations.
         Please expand your disclosures to specifically describe how increased
interest rates impact
         your results of operations, including:

                Changes to your pricing strategy in the near-term, including
how you consider
              customer sensitivity to price increases;
                Adjustments to your planned capital expenditures;
                The impact on liquidity resulting from your material
variable-rate debt outstanding.

         Please also expand your discussion of interest rates to describe their
impact on your
         financial condition, including your balance sheet. For example, given
rising rates,
         describe any resulting impacts on your long-term debt, or accrued
expense balances.
         Expand your disclosure to describe how you are funding these
additional costs.
       Please contact Taylor Beech at 202-551-4515 or Jennifer L  pez Molina at
202-551-3792
with any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services
cc:      Cathy A. Birkeland, Esq.