SecProbe.io

April  2, 201 5

Michael Z. Barkin
Executive Vice President  Finance and Chief Financial Officer
Vail Resorts , Inc.
390 Interlocken Crescent
Broomfield, CO 80021

Re: Vail Resorts , Inc.
 Form 10-K for Fiscal Y ear Ended July 31, 2014
Filed September  24, 201 4
File No. 001-09614

Dear Mr. Barkin :

We have reviewed your filing an d have the following comment s.  Our comment s ask you
to provide us with information so we may better understand your disclosure s.

Please respond to this letter within ten business days by confirming that you will revise
your document in future filings and providing the requested information.   If you do  not believe
our comment s applies to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comment s, we may
have  additional comments.

Financial Statement Notes

Note 2:  Summary of Significant Accounting Policies

Revenue Recognition , page F-10

1. You disclose on page 7 that the Epic Pass provides access to mountain resorts in France,
Switzerland and Japan.  It appears that you do not own any ski facilities in these countries.
Please explain to us how you recognize revenues and expenses, if any, along with their
amounts for the reporting periods presented related to the use of Epic Passes in these
countries.  Also, tell us whether you are the primary obligor in this situation and whether you
have any obligation to the  resorts in these countries associated with the Epic Pass.  We may
have further comment.

2. We note your revenue recognition polices for non -refundable and refundable private club
initiation fees.  For refu ndable initiation fees, you state that the difference between the
amount paid by the member and the present value of the refund obligation is recorded as
deferred initiation fee revenue and is recognized as revenue on a straight -line basis over 30

Michael Z. Barkin
Vail Resorts , Inc.
April 2 , 2015
Page 2

 years.  In that regard, tell us how you estimate the amount of the refund obligation at the end
of 30 years.   To the extent that the amounts are material and involve significant judgment and
estimates, please disclose how you make estimates in this area in critica l accounting policies
in MD&A.  Refer to SEC Release No. 33 - 8350.

Note 16:  Stock Compensation Plan, page F -30

3. It appears the disclosures required by ASC 718 -10-50-2(e) have not been provided.   Please
revise as appropriate.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from  taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Patrick Kuhn  at (202) 551 -3308  or Doug Jones at (202) 551 -3309  with any
questions .  You may also call me at (202) 551 -3380.

Sincerely,

 /s/ Melissa Raminpour for

Lyn Shenk
Branch Chief