SecProbe.io

September 19, 2013
Via E -mail
Mark E. Speese
Chairman of the Board and Chief Executive Officer
Rent -A-Center, Inc.
5501 Headquarters Drive
Plano, Texas  75024

Re: Rent -A-Center, Inc.
  Registration Statement on Form S-4
Filed  August 2 7, 2013
  File No.  333-190830

Dear Mr. Speese :

We have limited our review of your registration statement to those issues we have
addressed in our 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 amending your registration statement and providing the
requested information .  Where 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 any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

Supplemental Letter

1. We note your supplemental letter filed as correspondence.  Please revise your
supplemental letter to include the following:

 The Registrant further represents that, with respect to any broker -deale r that
participates in the Exchange Offer with respect to Privately Placed Notes acquired for
its own account as a result of market -making activities or other trading activities, each
such broker -dealer must confirm that it has not entered into any arrange ment or
understanding with the Registrant or an affiliate of the Registrant to distribute the
Registered Notes.

Acceptance of Outstanding Notes for Exchange; Issuance of Exchange Notes, page 31

2. Please revise to state that the issuer will issue the new no tes or return the old notes
promptly after expiration rather than after acceptance.  See Exchange Act Rule 14e -1(c).

Mark E. Speese
Rent -A-Center, Inc.
September 19, 2013
Page 2

 Note Guarantees, page 43

3. We note disclosure on page 43 that the guarantees are joint and several.  Please revise to
also clarify, if accur ate, that each guarantor subsidiary is “100% owned” as defined in
Rule 3 -10(h) and clarify whether each guarantee is “full and unconditional”.

Signatures, page II -14

4. Please revise to include the signature of the principal executive officer, principal financial
officer, controller or principal accounting officer and at least a majority of the board of
directors of each of your additional registrants.  Any person who occ upies more than one
position shall indicate each capacity in which he or she signs the report .  See Instruction
(2) of Form S -4.

Legal Opinion, Exhibit 5.4

5. Please have counsel revise its opinion as follows:

 Please delete the assumption in section (iv) o n page 3.  This assumption is overly
broad ; and

 We note the statement on page 6 that this opinion has been provided solely for the
benefit of the Local Guarantor and no other person or entity shall be entitled to rely
hereon without the express written consent of the Local Guarantor and the
undersigned.  Please have counsel revise the opinion to delete such language.  Please
refer to Sections II(B)(3)(a) and (d) of Staff Legal Bulletin No. 19.

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 Act of 193 3 and
all applicable Securities  Act rules require.   Since the company 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.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

Mark E. Speese
Rent -A-Center, Inc.
September 19, 2013
Page 3

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

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act o f 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Sherry Haywood, Staff Attorney at  (202) 551 -3345  or, in her absence,  me
at (202) 551 -3760  with any questions.

Sincerely,

 /s/ Pamela Long

 Pamela Long
Assistant Director

Cc: Via E -mail
 Thomas W. Hughes, Esq.