SecProbe.io

CORRESP
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HERTZ
GLOBAL HOLDINGS, INC.

225 Brae Boulevard

Park Ridge, NJ 07656

November 13, 2006

Securities and
Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Registration
Statement on Form S-1

of Hertz Global Holdings, Inc.

File No.
333-135782

Ladies and Gentlemen:

Pursuant to the
provisions of Rule 461 under the Securities Act of 1933, as amended, Hertz
Global Holdings, Inc., a Delaware corporation (the “Registrant”), hereby
respectfully requests that the effective date of the above-referenced
Registration Statement be accelerated so as to permit it to become effective at
3:00 P.M. (EST) on November 15, 2006 or as soon thereafter as possible.

The Registrant
hereby acknowledges that:

(i)             should
the Securities and Exchange Commission (the “Commission”) or the staff,
acting pursuant to delegated authority, declare the filing effective, it does
not foreclose the Commission from taking any action with respect to the filing;

(ii)            the
action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the Registrant from its
full responsibility for the adequacy and accuracy of the disclosure in the
filing; and

(iii)           the
Registrant 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.

[remainder of the page intentionally left blank]

  Very truly yours,

  HERTZ GLOBAL HOLDINGS, INC.

  By:

  /s/ PAUL J.
  SIRACUSA

  Name:

  Paul J. Siracusa

  Title:

  Executive Vice President and Chief

  Financial Officer

 2

November 13, 2006

Securities and
Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

  Re:

  Hertz Global Holdings, Inc.

  Filed on Form S-1

  Registration No. 333-135782

Ladies and Gentlemen:

In connection with the above-captioned
Registration Statement, we wish to advise that between October 27, 2006 and the
date hereof 36,995 copies of the Preliminary Prospectus dated October 27, 2006
were distributed as follows: 32,469 to 26 prospective underwriters; 4,360 to
4,360 institutional investors; 145 to 2 prospective dealers; 1 to 1 individual;
9 to 3 rating agencies and 11 to 11 others.

In connection with the
above-captioned Registration Statement, we also wish to advise that between
November 7, 2006 and the date hereof 2,900 copies of the Preliminary Prospectus
dated November 7, 2006 were distributed as follows: 2,475 to 25 prospective
underwriters and 425 to 425 institutional investors; and between November 13,
2006 and the date hereof 3,740 copies of the Preliminary Prospectus dated
November 13, 2006 were distributed as follows: 3,610 to 25 prospective
underwriters and  130 to 130
institutional investors

We have been informed by
the participating underwriters that they will comply with the requirements of
Rule 15c2-8 under the Securities Exchange Act of 1934.

We hereby join in the
request of the registrant that the effectiveness of the above-captioned
Registration Statement, as amended, be accelerated to 3:00pm EST on November
15, 2006 or as soon thereafter as practicable.

  Very truly yours,

  GOLDMAN, SACHS & CO.

  LEHMAN BROTHERS INC.

  MERRILL LYNCH, PIERCE, FENNER & SMITH
  INCORPORATED

  J.P. MORGAN SECURITIES INC.

  As Representatives of the

  Prospective Underwriters

  By:

  /s/ Goldman, Sachs & Co.

     (Goldman, Sachs & Co.)

  On behalf of the Representatives