SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE
March 18, 2011

Elyse Douglas Executive Vice Chairman and Chief Financial Officer
Hertz Global Holdings, Inc.
225 Brae Boulevard Park Ridge, New Jersey 07656-0713
 Re: Hertz Global Holdings, Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2010
  Filed February 25, 2011   File No. 1-33139
Dear Ms. Douglas:

We have limited our review of your filing to your  contacts with countries that have been
identified as state sponsors of terrorism, and we  have the following comments.  Our review with
respect to this issue does not prec lude further review by the Assist ant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we may
better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.  General

1. You disclose on pages 2 and 7 in your Form 10-K that you operate in Latin America,
Africa, and the Middle East, regions that can be understood to include Cuba, Sudan,
Syria, and Iran.  In addition, in your lette r dated November 2, 2006, you advised us that
you intended to maintain a presence in Syria through a franchisee or licensee.  It also
appears from public information that Hertz c onducts car rental operations in Syria.
 Cuba, Iran, Sudan, and Syria are identified by th e State Department as state sponsors of
terrorism, and are subject to U.S. economic sanctions and export controls.  You do not
include any information about contacts with those countries in your Form 10-K.  Please
describe to us your past, current, and anticip ated contacts with each  of the referenced
countries, whether through subsidiaries, aff iliates, franchisees, licensees, dealers,
independent contractors, or othe r direct or indirect arrangeme nts, since your  letter to us
dated November 2, 2006.  Your response should describe any goods, equipment, services,

Elyse Douglas
Hertz Global Holdings, Inc. March 18, 2011 Page 2
technology, or support that you have  provided into Cuba, Iran, Sudan, and Syria, directly
or indirectly, and any agreements, commercia l arrangements, or other contacts you have
had with the governments of those count ries or entities controlled by them.

2. Please tell us whether, to the best of your knowledge, understanding, and belief, any of
the goods, equipment, or technology, includ ing any air compressors, you have provided
or intend to provide, directly or indirectly, into Cuba, Iran, Sudan, and Syria are dual use
items.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts rela ting to the company’s disclosure , they are responsible for the
accuracy and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:

• the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.
 Please contact Pradip Bhaumik, Special Couns el, at (202) 551-3333 or  me at (202) 551-
3470 if you have any questions abou t the comments or our review.
          S i n c e r e l y ,              C e c i l i a  B l y e ,  C h i e f           Office of Global Security Risk   cc:  Max Webb   Assistant Director  Division of Cor poration Finance