SecProbe.io

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Mail Stop 3561

      	December 2, 2005

Via U.S. Mail

Christopher A. Taravella, Esq.
DaimlerChrysler Financial Services Americas LLC
27777 Inkster Road
Farmington Hills, MI  48334-5326

Re: 	DaimlerChrysler Financial Services Americas LLC
	Registration Statement on Form S-3
	Filed November 4, 2005
	File No. 333-127963

Dear Mr. Taravella:

      We have limited our review of your filing for compliance
with
Regulation AB.  Please further note that our limited review only
covers the issues that we have addressed in our comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your
explanation as
to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      The purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to
enhance
the overall disclosure in your filing.  We look forward to working
with you in these respects and welcome any questions you may have
about our comments or on any other aspect of our review.  Feel
free to
call us at the telephone numbers listed at the end of this letter.

General
1. Please note that our comments to either the supplement and/or
base
prospectus should be applied universally, if applicable.
Accordingly,
if comments issued for one apply to another, make conforming
revisions
as appropriate.  Also reflect these comments in any other
prospectus
supplement connected with this registration statement.  Please
confirm
to us in your response that you will comply with this instruction.
2. We note in various sections of the base prospectus your
statements
"unless otherwise specified in an accompanying prospectus
supplement"
or "as otherwise specified in a related prospectus supplement,"
which
appears to indicate that the specific terms you describe in the
base
prospectus will be different in the prospectus supplement.
However,
the disclosure in the prospectus supplement should not contradict
the
disclosure in the base prospectus.  Instead, please disclose all
assets, structural features, trust duties, selection criteria, and
credit enhancement that you reasonably contemplate including in
the
ABS offering.
3. We note that you indicate throughout the base prospectus that
you
will provide such things as credit enhancement or other features
that
were not described as contemplated in the base prospectus in the
related prospectus supplement.  Please see our related comments on
this point throughout the letter.  Please note that a takedown off
of
a shelf that involves assets, structural features, credit
enhancement
or other features that were not described in the base  prospectus
will
usually require either a new registration statement, if to include
additional assets, or a post-effective amendment.  Also, please
note
that Securities Act Rule 409 requires that the registration
statement
be complete at the time of effectiveness except for information
that
is not known or reasonably available.  Please revise the base
prospectus to describe the credit enhancement or other structural
features reasonably contemplated to be included in an actual
takedown.
Please see our comments below for guidance.
4. In the next amendment, please include, to the extent
practicable,
bracketed language showing both where you plan to include
information
in the prospectus supplement and what the substance of that
information will be in terms of compliance with Regulation AB.  We
believe this will not only enable us to better review your shelf
filing but that it will also make it less likely that any form
required information will not be inadvertently omitted.  See our
related comments below for more guidance.
5. Please confirm that all finalized agreements will be filed at
the
time of takedown. Please refer to Item 1100(f).
6. Please include a separately captioned section to disclose any
legal
proceedings pending against the sponsor, seller, servicer,
depositor,
trustees, issuing entity or other transaction parties that would
be
material to investors, if applicable.  Refer to Item 1117 of
Regulation AB.

7. Please add a separately captioned section to disclose the
affiliations and certain relationships and related transactions of
the
transaction parties referred to in Item 1119 of Regulation AB.
8. Please confirm that the depositor or any issuing entity
previously
established, directly or indirectly, by the depositor or any
affiliate
of the depositor have been current with Exchange Act reporting
during
the last twelve months with respect to asset-backed securities
involving the same asset class.  Please refer to General
Instruction
I.A.4. of Form S-3.  Also, please provide us with the CIK codes
for
any affiliate of the depositor that has offered a class of asset-
backed securities involving the same asset class as this offering.

Prospectus Supplement

Transaction Illustration, S-4
9. Please revise the diagram in to identify the sponsor, depositor
and
the issuing entity.

Transaction Summary, page S-5
Parties to the Transaction, page S-5
10. Please revise to include the administrator as a party to the
transaction.  We note your disclosure on page 58 of the base
prospectus.
11. Where applicable, please revise to identify transaction
parties
consistent with the definitions in Item 1101 of Regulation AB.
For
instance, it appears to us that "sellers" should be identified as
originators and issuer should be identified as "issuing entity."
Please also revise on the cover page of the supplement.

Flow of funds, page S-6
12. Please revise your diagram on page S-7 to indicate, generally,
the
point(s) in the flow of funds where credit enhancement providers
will
provide funds.  We note on page 29 of the base prospectus that you
contemplate various forms of credit enhancement.

Credit Enhancement, page S-8
13. Add bracketed language to the prospectus supplement to clarify
that you will provide the financial information as outlined in
Item
1114(b) if the aggregate significance percentage is 10% or more.

14. We note that you may enter into interest rate or currency
swaps.
Provide for disclosure of the descriptive information required by
Item
1115(a) of Regulation AB, including the significant percentage the
interest rate represents.  Likewise, provide the financial
information
as outlined in Item 1115(b) if the significant percentage is 10%
or
more.  Provide the language in brackets in the prospectus
supplement,
if applicable.
15. Confirm you will file any enhancement or support agreements
and
agreements related to the derivative instruments as exhibits.
Refer
to Instruction 1 to Item 1114(a) and Item 1115(a)(5),
respectively.

Selection Criteria, page S-16
16. Please describe any expenses incurred in connection with the
selection and acquisition of the pool assets payable from offering
proceeds or other transaction parties.  Refer to Item 1107(j) of
Regulation AB.

Yield Supplement Overcollateralization Amount, page S-36
17. Please revise to further describe and clarify the yield
supplement
overcollateralization amount, including its relation to
DaimlerChrysler Retail Receivables LLC as illustrated on page S-4.

Fees and Expenses of the Trust, page S-31
18. Please include a table itemizing all fees and expenses to be
paid
or payable out of the cash flows from the pool assets.  Refer to
Item
1113(c).  We suggest showing items paid out of the servicer`s fee
be
shown with footnotes or indented or in some other fashion to
provide a
comprehensive picture of where the fees are going.  Also, please
add
this section to the table of contents.

Owner Trustee and Indenture Trustee, page S-39
19. Please provide bracketed language to disclose prior experience
information for each trustee.  Refer to Item 1109(b) of Regulation
AB.

Base Prospectus

Reading this prospectus and the accompanying prospectus
supplement,
page 2
20. We note the second paragraph on this page.  We also note your
disclosure on page 18 that "the prospectus supplement for a series
will describe any material provisions...that differ in a material
way."  The information in the prospectus supplement should
complement
the information in the base, but should not "vary" or "differ."
Please revise accordingly.

Summary, page 7
Securities Issued, page 7
21. Please delete the last bullet "other relevant factors."

Trust Property, page 8
22. On November 17, 2005, your counsel informed us that you intend
to
revise your disclosure regarding "previously issued securities"
and
disclosure regarding the prefunding period.  Please revise
accordingly
in the base and the prospectus supplement.
23. Furthermore, please revise your summary in the prospectus
supplement to include bracketed language to disclose the
information
required by Item 1103(a)(5)(i), (ii), (iv), (v) and (vi), as
applicable.
24. Finally, please confirm that any prefunding period will comply
with Item 1101(c)(3)(ii) of Regulation AB, including that the
period
will not extend for more than one year from the date of issuance
and
that you will not use more than 50% of the proceeds of the
offering to
fund the account.

Enhancement, page 8
25. Refer to the last bullet point on page 9.  Please remove the
phrase "other arrangements similar to those described above."  If
you
are referring to other types of support, deposit or derivative
arrangements that are not disclosed in the list, please revise to
include them in the base prospectus.  Please note that forms of
credit
enhancement must meet the definition of an asset-backed security.

Sponsor, Depositor and Servicer, page 18
26. Please revise to discuss the size, composition and growth of
the
servicer`s portfolio of serviced assets.  Refer to Item 1108(b)(2)
of
Regulation AB.

Trust Property, page 21
27. We note you may use a revolving period.  Because your
securities
are backed by an asset pool that is not considered revolving in
nature, the revolving period may not extend for more than three
years
from the date of issuance.  Refer to Item 1101(c)(3)(iii) of
Regulation AB.  Please revise or advise.

28. Furthermore, with regard to the revolving period, please
include
bracketed language to disclose in the prospectus supplement the
information required by Item 1103(a)(5)(i), (iii), (iv), (v) and
(vi),
as applicable.
29. Please revise to disclose whether there are any differences in
the
underwriting criteria the revolving or prefunding period from the
criteria used to select the current asset pool.  See Item
1111(g)(7).

Precomputed Receivables, page 24
30. Please revise to further describe the actuarial method.
Please
include the party that determines the payment allocation and when
it
is determined.  Also, discuss any differences between receivables
computed under the simple interest method and the actuarial method
that would be material to investors.
31. Please revise to briefly describe the "Rule of 78`s" method.
32. Please refer to the last sentence that appears on page 25.
Please
revise to quantify what you mean by a "portion."  Also please
clarify
under "Balloon Note Receivables."

Balloon Note Receivables, page 25
33. We note that DaimlerChrysler Retail Receivables LLC will have
the
option to transfer "Fixed Value Payments to the related trust in
exchange for certificates representing interests in these final
Fixed
Value Payments or indebtedness secured by these Fixed Value
Payments."
It seems that you contemplate adding assets to the pool at some
future
date.  Please tell us how this structural feature meets the
discrete
pool requirement of an asset-backed security.  Refer to Item
1101(c)(1) of Regulation AB.  We also note your disclosure on page
9
that "after issuing the securities described in a prospectus
supplement, the related trust will not issue any additional
securities."

Static Pool Data, page 27
34. Please provide us with all of the static pool information that
will be provided in response to Item 1105 of Regulation AB when it
becomes available.  Also, please disclose the specific website
address
in the prospectus supplement.  Refer to Rule 312(a)(1) of
Regulation
S-T.

Credit and Other Enhancements, page 28
35. We note that you may use "purchase obligations" as credit and
cash
flow enhancement.   Please confirm and explain whether this type
of
asset meets the definition of an asset-backed security.  Refer to
Item
1101(c)(1) and Item 1114 of Regulation AB.
36. Refer to the second to last bullet point of this section on
page
29.  Please revise to delete your reference to other agreements
with
respect to third party payments.  We view this as a catch-all.
Instead, disclose all forms of credit enhancement reasonably
contemplated to be included in an actual takedown.

Payments on the Securities, page 30
37. We note that a class of securities may be redeemable.  Please
expand your disclosure to further describe this feature.  Please
address when the securities may be redeemed and whether the holder
has
the discretion to redeem the securities.

Interest Payments, page 32
Floating Rate Securities, page 32
38. Please revise your disclosure to explain how the interest
rates
will be determined and how frequently interest rates will be
adjusted.
Refer to Item 1113(a)(3) of Regulation AB.  Please also add
bracketed
language in your prospectus supplement where applicable.

Sale Provisions, page 38
39. We note that "unless otherwise provided in the related
prospectus
supplement" proceeds from the offering will be used to purchase
related receivables and/or fund a related prefunding account.
Please
revise to disclose the other purposes for which you may use the
offering proceeds.

Reports to be filed with the SEC, page 44
40. We note your disclosure on page 45 that "unless specifically
stated in the report, the reports and any information included in
the
report will neither be examined nor reported on by an independent
public accountant."  Please note that an attestation report of a
registered public accounting firm that attests to and reports on,
the
assessment of compliance with servicing criteria must be filed as
an
exhibit to the Form 10-K report.  Please note that the
substitution of
another type of accountant`s report or opinion will not satisfy
the
reporting requirements.  Please revise your disclosure to
accurately
reflect the reporting requirements for asset-backed securities
pursuant to Securities Act Rule 15d-18.

Evidence as to Compliance, page 45
41. We note that your form of Sale and Servicing Agreement filed
as
exhibit 99.1 requires a servicer compliance statement and an
auditor`s
report by April 30th or approximately one month after it is
required
to be filed with the Form 10-K.  Please revise the underlying
agreements to comply with Regulation AB and file them as exhibits.

* * * * *

      As appropriate, please amend the registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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 th