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Mail Stop 4561
         August 5, 2008
Mr. Stephen P. Holmes Chief Executive Officer   Wyndham Worldwide Corporation Seven Sylvan Way Parsippany, NJ   07054

Re: Wyndham Worldwide Corporation
  Form 10-K for the year ended December 31, 2007
  Filed 02/29/08
File No. 001-32876
 Dear Mr. Holmes:
We have reviewed your response letter dated June 30, 2008 and have the
following additional comments.  Where indicated, we think you should revise your documents in response to these comments in future filings.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detaile d as necessary in your explan ation.  After reviewing this
information, we may raise additional comments.   Please understand that the purpose of our re view 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.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 10-K for the year ended December 31, 2007

General

1. We note your response to our comment.  To the extent that you continue to refer
to valuation specialists in future filings, please clarify their role in your disclosure
similar to the information included in your response to us.

Mr. Stephen P. Holmes
Wyndham Worldwide Corporation
August 5, 2008 Page 2
Consolidated and Combined Statements of Income, page F-3

2. We note your response to our comment.  In future filings, please revise your
statements of operations to include a sepa rate expense line item for the cost of
your consumer financing revenues in accordance with Rule 5-03(b)(2) of
Regulation S-X.
 Consolidated and Combined Statements of Cash Flows, page F-5

3. We note your response to comment 4.  You state that your rest ricted cash relates
to deposits on VOI sales and cash collected  from consumer receivables that are
collateral for the asset-backed borrowi ngs.  Based on paragraph 87 of SFAS 95
which states that appropria te classification generally should depend on the nature
of the activity that is likely to be th e predominate source of cash flows for the
item, it does not appear to us that the cash flows related to the changes in your restricted cash should be classified as investing cash flows.  Please explain.

Note 19 – Segment Information, page F-37

4. Please tell us what consideration you ga ve to presenting your consumer financing
operations as a separate reportable se gment in accordance with SFAS 131.

******

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  understand that we may have additional
comments after reviewing your responses to our comments.

 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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filing.

Mr. Stephen P. Holmes
Wyndham Worldwide Corporation August 5, 2008 Page 3
You may contact Jessica Ba rberich at (202) 551-3782 or  me at (202) 551-3486 if
you have questions regarding comments on the financial statements and related matters.
           S i n c e r e l y ,
Daniel Gordon  Branch Chief