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                               January 17, 2023

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

                                                        Re: UL Inc.
                                                            Amendment No. 5 to
Draft Registration Statement on Form S-1
                                                            Submitted December
22, 2022
                                                            CIK No. 0001901440

       Dear Jennifer F. 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. 5 to Draft Registration Statement on Form S-1

       Risk Factors
       Compliance with China's new laws, regulations and guidelines relating to
data privacy..., page 39

   1.                                                   We note your revised
disclosure in this risk factor and your response to our prior
                                                        comments that you do
not believe you or UL-CCIC are subject to CAC regulations.
                                                        Please include a
statement to that effect in this risk factor and discuss the basis on which
                                                        you made that
determination.
 Jennifer F. Scanlon
FirstName
UL Inc. LastNameJennifer F. Scanlon
Comapany
January  17,NameUL
             2023   Inc.
January
Page 2 17, 2023 Page 2
FirstName LastName
Notes to the Condensed Consolidated Financial Statements
1. Significant Accounting Policies
Basis of Presentation, page F-56

2.       In changing the inputs used to estimate the revenue recognition, you
state that project
         phase data was not previously available. Please tell us why it was not
available and the
         circumstances that changed to make this data available.
       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 Jennifer L  pez Molina at 202-551-3792
with any other
questions.



                                                              Sincerely,

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