SecProbe.io

February 3, 2020
Michael Z. Barkin
Executive Vice President and Chief Financial Officer
Vail Resorts, Inc.
390 Interlocken Crescent
Broomfield, Colorado 80021
Re:Vail Resorts, Inc.
Form 10-K for the Fiscal Year Ended July 31, 2019
Filed September 26, 2019
File No. 001-09614
Dear Mr. Barkin:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended July 31, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 41
1.Please expand your results of operations discussion to quantify the impact of each factor
identified as causing changes in results between periods.  For example, we note that
Mountain Reported EBITDA increased as a result of strong North American pass sales
growth, strong growth in visitation and spending at western U.S. resorts, and recent
acquisitions.  Please quantify the impact of each factor attributing to the increase, here,
and throughout your discussion, in accordance with Item 303(a)(3)(iii) of Regulation S-K
and Section III.D of SEC Release No. 33-6835.
Reconciliation of Segment Earnings, page 49
2.Please revise your presentations of non-GAAP measures to begin reconciliations with
GAAP results rather than non-GAAP results.  See Question 102.10 of the Compliance

 FirstName LastNameMichael Z. Barkin
 Comapany NameVail Resorts, Inc.
 February 3, 2020 Page 2
 FirstName LastName
Michael Z. Barkin
Vail Resorts, Inc.
February 3, 2020
Page 2
& Disclosure Interpretations on The Use of Non-GAAP Financial Measures.  Please note
that this comment also applies to your Form 10-Q and earnings releases.
Contractual Obligations, page 54
3.We note that the line item "Purchase Obligations and Other" in the Table of Contractual
Obligations includes amounts for trade payables, accrued payroll and benefits, accrued
fees and assessments, contingent consideration liability, and accrued taxes, which
are already included on the balance sheet.  Please tell us why you believe these items meet
the criteria in Item 303(a)(5)(ii)(D) of Regulation S-K to be included in the table.

            In closing, 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 Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services