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                            April 27, 2020

       Paul Seavey
       Executive Vice President and Chief Financial Officer
       Equity Lifestyle Properties, Inc.
       Two North Riverside Plaza
       Suite 800
       Chicago, IL 60606

                                                        Re: Equity Lifestyle
Properties, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed February 24,
2020
                                                            File No. 001-11718

       Dear Mr. Seavey:

             We have reviewed your filing and have the following comment. In
our comment, we
       may ask you to provide us with information so we may better understand
your disclosure.

              Please respond to this comment 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 our
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 10-K for the fiscal year ended December 31, 2019

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations, page 44

   1.                                                   We note your disclosure
of your results of operations. Please tell us what consideration
                                                        you gave to presenting
your discussion of material changes from year to year in a way
                                                        that corresponds to the
line items on your Consolidated Statements of Income or your
                                                        segment disclosure.
Please refer to Item 303 of Regulation S-K and SEC Release No. 33-
                                                        8350.
 Paul Seavey
FirstName LastNamePaul Seavey
Equity Lifestyle Properties, Inc.
Comapany NameEquity Lifestyle Properties, Inc.
April 27, 2020
Page 27,
April 2 2020 Page 2
FirstName LastName
        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.

       You may contact Babette Cooper at 202-551-3396 or Jennifer Monick at
202-551-3295 if
you have questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Real Estate
& Construction