SecProbe.io

Mail Stop 3561

May 31, 2007

Via U.S. Mail & Facsimile (212) 521-7036
Harold Rolfe, Esq.
Senior Vice President, Gene ral Counsel and Secretary
Hertz Global Holdings, Inc.
225 Brae Boulevard
Park Ridge, NJ  07656-0713

Re:  Hertz Global Holdings, Inc.
 Registration Statement on Form S-1
 Filed May 21, 2007
 File No. 333-143108

Dear Mr. Rolfe,

We have limited our review of your filing to  those issues we have addressed in our
comments.  Where indicated, we think you s hould 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 comment s, we may ask you to provide us with
information so we may better understand your  disclosure.  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.

Underwriting, page 186

Please disclose any trading that you are awar e of by Merrill Lynch & Co. in the securities
of Hertz Global Holdings, Inc. since your  initial public offering, summarize possible
securities law violations, and provide anticipated disgorgement to you from Merrill Lynch, if any.

*********************

Harold Rolfe, Esq.
Hertz Global Holdings, Inc.
May 31, 2007 Page 2
As appropriate, please amend the regist ration 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 c over 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 amendmen t 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 info rmed 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.

Notwithstanding our comments, in the even t the company request s acceleration of
the effective date of the pending registration st atement, it should furnish a letter, at the time
of such request, acknowledging that

• Should the Commission or the staff, acti ng pursuant to delegated authority,
declare the filing effective, it does no t 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 effectiv e, does not relieve th e company from its
full responsibility for the adequacy and accu racy of the disclosu re in the filing;
and
• The company may not assert this action as  a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.

We will consider a written request for acceleration of the effective date of the
registration statement as a confirmation of th e fact that those reque sting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acceleration of the effective date.

We direct your attention to Rules 460 and 461 regarding requesting acceleration of
a registration statement.  Please allow adequate  time after the filing of any amendment for
further review before submitting a request for acceleration.  Please provide this request at
least two business days in advance of the requested effective date.

Harold Rolfe, Esq.
Hertz Global Holdings, Inc.
May 31, 2007 Page 3
Please contact Joshua Ravitz at (202 ) 551-4817 or me at (202) 551-3750 with any
other questions.

Regards,

Max A. Webb
 Assistant Director

cc: Via Facsimile (212) 521-7036
 Steven Slutzky, Esq.
Debevoise & Plimpton LLP