SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
CF/AD5
100 F STREET, NE
WASHINGTON, D.C. 20549-3561

       DIVISION OF
CORPORATION FINANCE

        July 3, 2008

Via Mail and Fax

Elyse Douglas
Executive Vice President and Chief Financial Officer
   and Treasurer
Hertz Global Holdings, Inc. 225 Brae Boulevard Park Ridge, NJ 07656

 RE:  Hertz Global Holdings, Inc.,
  The Hertz Corporation
   Form 10-Q for the Period Ended March 31, 2008
   File Numbers: 001-06075, 001-07541

Dear Ms. Douglas:

 We have reviewed your correspondence dated May 21, 2008 and have the following comments.  Where indicated, we be lieve you should revise future filings in
response to certain of these comments.  If you disagree, we will consider your
explanation as to why a revisi on is unnecessary.  Please be as  detailed as necessary in
your explanation.  We also ask you to provi de us with further information.  After
reviewing the additional information, we may raise further comments.  Please file your
response to our comments via EDGAR, under the label “corresp,” within 10 business
days from the date of this letter.

Hertz Global Holdings, Inc.

Form 10-Q for the Period Ended March 31, 2008

Notes to Condensed Consolidated Financial Statements, page 6
Note 10 – Segment Information, page 19

1. We believe that “other reconciling items” relative to “adjusted pre-tax income (loss)”
should be presented as an adjustment in  reconciling the sum of the segments’
“adjusted pre-tax income (loss)” to cons olidated “loss before income taxes and
minority interest.”  In your current pres entation, you are arrivi ng at a consolidated
amount for “adjusted pre-tax income (loss)” that is not relevant to your reportable
segments.  Furthermore, as “adjusted pre- tax income (loss)” of the segments is a

Hertz Global Holdings, Inc., The Hertz Corporation
July 3, 2008
Page 2 of 3
subset of consolidated “loss before income taxes and minority interest,” we believe it
is preferable to reconcile from the sum of the segments’ “adjusted pre-tax income (loss)” to consolidated “loss before income  taxes and minority interest,” and not the
other way around as currently presented.  Pl ease revise your presentation accordingly.

Note 14 – Fair Value Measurements, page 23

2. Pursuant to paragraph 36.a of FAS 1 57, as amended by paragraph 11 of FSP FAS
157-2, delayed application of FAS 157 is permitted for nonfinancial assets and
nonfinancial liabilities, except for items that are recognized or disclosed at fair value
in the financial statements on a recurring basis (at least annually).  However, your
disclosure implies that you have delayed th e application of FA S 157 for all of your
nonfinancial assets and nonfinancial liabilities, whether recognized or disclosed at
fair value on a recurring or nonrecurring basis.  In this re gard, please represent to us
and clarify your disclosure in your next Form 10-Q that you have applied FAS 157 to all nonfinancial assets and nonf inancial liabilities that ar e recognized or disclosed at
fair value on a recurring basi s.  If this is not the case, please identify and quantify,
based on amounts at which reported on March 31, 2008, for us the recurring nonfinancial assets and nonfinancial liab ilities for which you have not applied FAS
157, and give us your reasoning why you did not apply FAS 157 to these items.  Additionally, in your next Form 10-Q and thereafter until FAS 157 has been applied
to all assets and liabilities within its scope , disclose each major category of assets and
liabilities that are recognized or disclose d at fair value on a nonrecurring basis for
which you have not applied the provisions of FAS 157, pursuant to paragraph 12.b of
FSP FAS 157-2.  Provide us with a copy of your intended disclosures.

Derivative Instruments and Hedging Activities, page 24

3. Please explain to us where the total change in the fair value of the liability for the HVF Swaps between March 31, 2008 and December 31, 2007 ($144.7 million and $50.2 million, respectively) of $94.5 million is re ported in your financial statements.
It appears that $55.7 million of the change  was recorded in accumulated other
comprehensive income as the effective portion of the cash flow hedge, and that $2.3 million of the change was charged to earni ngs in the quarter ended March 31, 2008 as
the ineffective portion of the hedge.

The Hertz Corporation

4. Please conform the relevant disclosures in the corresponding filings of The Hertz Corporation to the comments indicated a bove for Hertz Global Holdings, Inc., as
appropriate.

Hertz Global Holdings, Inc., The Hertz Corporation
July 3, 2008
Page 3 of 3
Other

5. In connection with responding to our comments, please provide, in writing, a statement acknowledging that:
‚ you are responsible for the adequacy and accuracy of the disclosures in your
filings;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and
‚ you may not assert staff comments as a de fense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

You may contact Doug Jones at 202-551-3309 or Lyn Shenk at 202-551-3380
with any questions.  You may also contact me at 202-551-3816.

 Sincerely,

 Joseph Foti
Senior Assistant Chief Accountant