SecProbe.io

April  29, 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
Response dated April 14, 2015

Dear Mr. Barkin :

We have reviewed your  response letter dated  April  14, 2015  and have the following
comments.  O ur comments  ask you  to provide us with information so we may better understand
your disclosure.

Please respond to this letter within ten business days by providing the requested
information.   If you do not believe our comments applies to your facts and circumstances, please
tell us why in your response.

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

Financial Statem ent Notes

Note 2: Summary of Significant Accounting Policies

Revenue Recognition , page F-10

1. Refer to your response to prior comment 2.  You state that the refundable initiation fees are
subject to an unconditional refund 30 years from the effective date  of membership.   You
disclose that for fees that are refundable in 30 years after the date of acceptance of a member,
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 years.  Please tell us the basis for your accounting treatment and
the guidance you relied on in recognizing and classifying the accretion as revenue for fees
that are fully refundable.   In so doing, please tell us how your treatment complies with SAB
Topic 13 .A.4.a.

Michael Z. Barkin
Vail Resorts, Inc.
April  29, 2015
Page 2

 2. We note on the website www.discovermembership.com  that you have a number of signature
clubs.  We note that a number of t he deposits for membership therein, which we believe to be
the same as the initiation fees referred to in the preceding comment, are refundable to varying
degrees (for example, 100%, 80%, 50%, etc.).  Please correspond for us the initiation fees
refundable  in 30 years referred to in the preceding comment to your specific club
memberships.  In addition, tell us the following in regard to the deposits/initiation fees
required for memberships in these clubs:

 All of the types of deposits/fees that are refundable, and the terms and conditions upon
which such are refundable, including any time periods or events associated with a refund
(for example, in 30 years, upon resignation, etc.).
 Your accounting treatment for each type of refundable deposit/fee.
 The amount of revenue recognized in each of the last 3 years for deposits/fees that are
refundable.
 The aggregate balances at July 31, 2014 and the latest interim period end date practicable
of deposits that are nonrefundable and refundable, respectively, where each balance is
reported on the balance sheet, and any current portions of such balances.

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/ Lyn Shenk

Lyn Shenk
Branch Chief