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July 17, 2008

VIA EDGAR

Mr. Joseph Foti

Senior Assistant Chief Accountant

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3561

  Re:

  Hertz Global Holdings, Inc.

  The Hertz Corporation

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

  File Numbers: 001-33139, 001-07541

Dear Mr. Foti:

This letter sets forth the responses of Hertz Global
Holdings, Inc. (the “Company”) to the comments contained in your letter,
dated July 3, 2008, relating to the Hertz Global Holdings, Inc. Form 10-Q
for the period ended March 31, 2008 filed with the Securities and Exchange
Commission (the “Commission”) on May 9, 2008 and The Hertz Corporation Form 10-Q
for the period ended March 31, 2008 filed with the Commission on May 12,
2008.  The comments of the Commission are
set forth in bold/italicized text below, and the Company’s responses are set
forth in plain text immediately beneath each comment.

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 consolidated “loss before income taxes and minority
interest.” In your current presentation, you are arriving 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 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.  Please revise your
presentation accordingly.

In response to the Staff’s comment, the Company will
revise its disclosure in future filings to include a total of its reportable
segments’ “adjusted pre-tax income (loss)” and will reconcile this amount to
consolidated “income (loss) before income taxes and minority interest.”

For the Staff’s convenience, the Company has included
below its revised presentation of the reconciliation included within the
segment footnote:

  Three Months Ended March 31,

  Revenues

  Adjusted Pre-Tax Income

  (Loss)

  2008

  2007

  2008

  2007

  Car rental

  $

  1,626.2

  $

  1,529.7

  $

  39.3

  $

  36.9

  Equipment rental

  411.0

  389.9

  59.3

  65.6

  Total reportable segments

  2,037.2

  1,919.6

  98.6

  102.5

  Other reconciling items

  2.0

  1.9

  (81.5

  )

  (86.4

  )

  Total Company

  $

  2,039.2

  $

  1,921.5

  17.1

  16.1

  Less:

  Purchase accounting(a)

  24.8

  23.1

  Non-cash debt charges(b)

  14.5

  48.4

  Restructuring charges

  19.6

  32.6

  Restructuring related
  charges

  3.5

  —

  Unrealized loss on
  derivatives(c)

  6.0

  —

  Vacation accrual
  adjustment(d)

  3.2

  —

  Management transition costs

  1.3

  2.6

  Loss before income taxes
  and minority interest

  $

  (55.8

  )

  $

  (90.6

  )

  (a)

  Represents the purchase accounting
  effects of the Acquisition and any subsequent acquisitions on our results of
  operations relating to increased depreciation and amortization of tangible
  and intangible assets and accretion of revalued workers’ compensation and
  public liability and property damage liabilities.

  (b)

  Represents non-cash debt charges
  relating to the amortization of deferred debt financing costs and debt
  discounts. For the three months ended March 31, 2008, also includes $2.3
  million associated with the ineffectiveness of our HVF swaps. For the three
  months ended March 31, 2007, also includes the write-off of $16.2
  million of unamortized debt costs associated with a debt modification and
  $12.8 million associated with the ineffectiveness of our HVF swaps.

  (c)

  For the three months ended
  March 31, 2008, represents an unrealized loss on our interest rate
  swaptions.

  (d)

  Represents an increase in the employee
  vacation accrual during the three months ended March 31, 2008 relating
  to a change in our U.S. vacation policy in the second quarter of 2007, which
  now provides for vacation entitlement to be earned ratably throughout the
  year versus the previous policy which provided for full vesting on
  January 1 of each year.

Note 14 — Fair Value Measurements, page 23

2.              Pursuant to paragraph 36.a
of FAS 157, 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 the application of FAS 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
regard, 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 nonfinancial
liabilities that are recognized or disclosed at fair value on a recurring
basis.  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 liabilities 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 disclosed 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.

In response to the Staff’s comment, the Company
advises the Staff that it has adopted the provisions of
FAS 157 except as they relate to its nonfinancial assets and liabilities that
are not recognized or disclosed at fair value in the financial statements on a
recurring basis (at least annually).

The Company will revise its disclosure concerning the
adoption of FAS 157 in future filings.
For the Staff’s convenience, the Company has included below its revised
disclosure, in bold italicized and strikethrough text:

Note 14—Fair Value Measurements

Effective January 1, 2008, we adopted SFAS
No. 157 as it relates to our financial assets and liabilities.  The  the provisions of SFAS No.
157 are effective for us for  except as they relate to our non-financial assets and liabilities that are not recognized or disclosed at fair value
in the financial statements on a recurring basis (at least annually), whose provisions
become effective for us  beginning in January 2009. SFAS No. 157 defines fair value, establishes a
framework for measuring fair value in accordance with GAAP and expands
disclosures about fair value measurements.
SFAS No. 157 establishes a three-tier value hierarchy, which prioritizes
the inputs used in measuring fair value as follows: (Level 1) observable inputs
such as quoted prices in active markets; (Level 2) inputs other than the quoted
prices in active markets that are observable either directly or indirectly; and
(Level 3) unobservable inputs in which there is little or no market data, which
require the reporting entity to develop its own assumptions.

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 reported 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
earnings in the quarter ended March 31, 2008 as the ineffective portion of
the hedge.

In response to the Staff’s comment, the Company
advises the Staff that $55.7 million of the change in fair value, representing
the effective portion of the hedge, was recorded in “Accumulated other
comprehensive income,” net of $36.5 million of tax, which was included in “Deferred
taxes on income” in our Condensed Consolidated Balance Sheet.  Additionally, $2.3 million, representing the
ineffective portion of the hedge, was charged to earnings through “Interest, net of
interest income,” in our Consolidated Statement of Operations.

The
Company supplementally advises the Staff that it will disclose in future
filings the tax effect of the change in the fair value of the derivative
recorded to “Accumulated other comprehensive income.”

The Hertz Corporation

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

In response to the Staff’s comment, the Company will
conform all relevant revised disclosures made in the Hertz Global Holdings, Inc.
filings in the corresponding future filings of The Hertz Corporation.

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 defense in any proceeding initiated by the Commission or any
  person under the federal securities laws of the United States.

The Company acknowledges that it is responsible for
the adequacy and accuracy of the disclosures in its 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 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.

*  *
*  *  *
*  *

If you have any questions regarding this letter,
please do not hesitate to call me at (201) 307-2271.

  Sincerely,

  /s/ Elyse Douglas

  Elyse Douglas

  cc:

  Doug Jones

  Lyn Shenk

  Securities and Exchange
  Commission

  Steven J. Slutzky

  Debevoise &
  Plimpton LLP

  Jatindar Kapur

  Jeffrey Zimmerman

  Hertz Global Holdings, Inc.