SecProbe.io

August 1 , 2012

Via E -mail
Thomas G. Conforti
Chief Financial Officer
Wyndham Worldwide Corporation
22 Sylvan Way
Parsippany, New Jersey 07054

Re: Wyndham Worldwide Corporation
 Form 10-K for the fiscal year ended December 31, 2011
  Filed February  17, 2012
File No. 001-32876

Dear Mr. Conforti :

We have reviewed your filing an d have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comment  applies 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 filing and the information you provide in
response to this comment, we may have  additional c omments.

Item 1A Risk Factors, page 31

Failure to maintain the security of personally identifiable and other information …, page 36

1. We note you disclose that you and your service providers collect and retain significant
volumes of certain ty pes of personally identifiable and other information pertaining to
your customers, stockholders and employees and that a significant actual or potential
theft, loss, fraudulent use or misuse of customer, stockholder, employee or your data by
cybercrime or otherwise could adversely impact your reputation and could result in
significant costs, fines, litigation or regulatory action against you. We note the disclosure
in your latest Form 10 -Q referencing “three prior data breach incidents involving a group
of Wyndham brand hotels.”   Beginning with your next Form 10 -Q, please state that you
have experienced data breach incidents in the past in order to provide the proper context
for your risk factor disclosure.  Please refer to the Division of Corporation Finan ce’s
Disclosure Guidance Topic No. 2 at

Thomas G. Conforti
Wyndham Worldwide Co rporation
August 1, 2012
Page 2

 http://www.sec.gov/divisions/corpfin/guidance/cfguidance -topic2.htm  for additional
information.

We urge all persons who are respons ible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in posses sion of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the comp any is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

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

You may contact Kristi Marrone at (202) 551 -3429  or Jonathan Wiggins at (202) 551 -
3694  if you have questions regarding the financial statements and related matters.  Please contact
me at (202) 551 -3401 with any other questions.

Sincerely,

 /s/ Jennifer Gowetski

Jennifer Gowetski
Senior Counsel