SecProbe.io

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 April 21, 2025

Jessica P. Ross
Senior Vice President and Chief Financial Officer
Frontdoor, Inc.
3400 Players Club Parkway
Memphis, TN 38125

 Re: Frontdoor, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 001-38617
Dear Jessica P. Ross:

 We have completed our review of your filings. We remind you that the
company and
its management are responsible for the accuracy and adequacy of their
disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of Corporation
Finance
 Office of Trade &
Services
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</DOCUMENT>

CORRESP
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 CORRESP

     Jessica P. Ross Senior Vice President and Chief Financial Officer     April 15, 2025     VIA EDGAR   Division of Corporation Finance Office of Real Estate & Construction Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549   Attention: Valeria Franks and Keira Nakada   Re: Frontdoor, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Item 2.02 Form 8-K filed February 27, 2025 File No. 001-38617   Dear Ms. Franks and Ms. Nakada:   Frontdoor, Inc. (the “Company,” “we” or “our”) is submitting the following response to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission dated April 2, 2025, regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2024 and Current Report on Form 8-K filed on February 27, 2025 in accordance with the Securities Exchange Act of 1934, as amended.   To assist your review, we have retyped the text of the Staff’s comment in italics below.   Item 2.02 Form 8-K filed February 27, 2025   Exhibit 99.1 Fourth-Quarter 2024 Results, page 2   1. When you present and/or discuss a non-GAAP measure in your earnings release, please also present and/or discuss the comparable GAAP measure in the same manner. For example, when you disclose period-over-period adjusted EBITDA bridge, also disclose period-over-period net income bridge. The narrative section analysis below the bridge also has similar issues to those described above. Refer to Question 102.10(a) of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations and Item 10(e)(1)(i) of Regulation S-K.   The Company respectfully acknowledges the Staff’s comment and will revise its presentation and discussion of non-GAAP measures in future filings (including earnings releases furnished on Form 8-K) to present and discuss the comparable GAAP measure in the same manner.

 Please do not hesitate to call me at (901) 422-9709 with any questions or further comments you may have or if you wish to discuss the above response.     Very truly yours,   FRONTDOOR, INC.   By: /s/ Jessica P. Ross___________ Name: Jessica P. Ross Title: Senior Vice President and Chief Financial Officer       cc: Frontdoor, Inc. Jeffrey A. Fiarman   cc: Simpson Thacher & Bartlett LLP Kenneth B. Wallach
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<DOCUMENT>
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<TEXT>
 April 2, 2025

Jessica P. Ross
Senior Vice President and Chief Financial Officer
Frontdoor, Inc.
3400 Players Club Parkway
Memphis, TN 38125

 Re: Frontdoor, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 Item 2.02 Form 8-K filed February 27, 2025
 File No. 001-38617
Dear Jessica P. Ross:

 We have reviewed your filings and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Item 2.02 Form 8-K filed February 27, 2025
Exhibit 99.1
Fourth-Quarter 2024 Results, page 2

1. When you present and/or discuss a non-GAAP measure in your earnings
release,
 please also present and/or discuss the comparable GAAP measure in the
same
 manner. For example, when you disclose period-over-period adjusted
EBITDA
 bridge, also disclose period-over-period net income bridge. The
narrative section
 analysis below the bridge also has similar issues to those described
above. Refer to
 Question 102.10(a) of the Non-GAAP Financial Measures Compliance and
Disclosure
 Interpretations and Item 10(e)(1)(i) of Regulation S-K.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 April 2, 2025
Page 2

 Please contact Valeria Franks at 202-551-7705 or Keira Nakada at
202-551-3659 if
you have any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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CORRESP
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Acceleration Request

 VIA EDGAR

March 8, 2019

Re:
 Acceleration Request for frontdoor, inc.

 Registration Statement on Form S-1 (File No. 333-230015)

 Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Sara von Althann

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, we attach the request of our client, frontdoor, inc., that effectiveness of the above-referenced Registration Statement be accelerated to 4:30 p.m., Washington, D.C. time, on March 12, 2019, or as
soon as practicable thereafter.

 Please call me at (212) 455-3352 with any questions.

Very truly yours,

/s/ Kenneth B. Wallach

Kenneth B. Wallach

 FRONTDOOR, INC.

150 Peabody Place

 Memphis,
Tennessee 38103

 March 8, 2019

 VIA
EDGAR

Re:
 frontdoor, inc.

 Registration Statement on Form S-1 (File
No. 333-230015)

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E. Washington,
D.C. 20549

 Attention: Sara von Althann

 Ladies and
Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, frontdoor, inc. (the “Company”) hereby requests
that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective at 4:30 p.m., Washington, D.C. time, on March 12, 2019, or as soon as practicable thereafter.

If you require any additional information with respect to this letter, please contact Kenneth B. Wallach (212-455-3352) of Simpson Thacher & Bartlett LLP.

Very truly yours,

FRONTDOOR, INC.

By:

/s/ Jeffrey A. Fiarman

Name:

Jeffrey A. Fiarman

Title:

Senior Vice President, General

Counsel and Secretary

CORRESP
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frontdoor, inc.

150 Peabody Place

Memphis, Tennessee  38103

September 6, 2018

Via EDGAR

Kim McManus

Office of Real Estate and Commodities
 Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C.  20549

Re:                             frontdoor, inc.
 Registration Statement on Form 10
 File No. 0001727263

Dear Ms. McManus:

Reference is made to the Registration Statement on Form 10 (File No. 0001727263) (as amended to date, the “Registration Statement”), filed by frontdoor, inc. (the “Company”) with the U.S. Securities and Exchange Commission (the “Commission”).

The Board of Directors of ServiceMaster Global Holdings, Inc. (“ServiceMaster”) has set September 14, 2018 as the record date for the distribution of shares of common stock of the Company (the “Shares”), which is expected to be effective at 12:01 a.m., Eastern Time, on October 1, 2018. ServiceMaster and the Company would like the Shares to commence trading on the Nasdaq Global Select Market on a “when issued” basis on September 13, 2018, one day prior to the record date. Accordingly, the Company hereby requests that the effective date for the Registration Statement be accelerated to 4:00 p.m., Eastern Time, on September 7, 2018, or as soon as practicable thereafter, pursuant to Section 12(d) of the U.S. Securities Exchange Act of 1934, as amended, and Rule 12d1-2 thereunder.

In connection with this request, the Company hereby acknowledges that:

·                  should the Commission or the Staff of the Commission (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;

·                  the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·                  the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If the Staff has any questions or comments concerning this letter, or if you require any additional information, please feel free to contact Karessa Cain of Wachtell, Lipton, Rosen & Katz at (212) 403-1128. We request that we be notified of the effectiveness of the Registration Statement by a telephone call to Ms. Cain and that such effectiveness also be confirmed in writing.

Very   truly yours,

FRONTDOOR, INC.

By:

/s/   Rexford J. Tibbens

Name:

Rexford   J. Tibbens

Title:

President   and Chief Executive Officer

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CORRESP
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[Letterhead of Wachtell, Lipton, Rosen & Katz]

August 1, 2018

Via EDGAR and Courier

Kim McManus

Office of Real Estate and Commodities
 Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C.  20549

Re:                             frontdoor, inc. (formerly known as AHS Holding Company, Inc.)
 Amendment No. 2 to Draft Registration Statement on Form 10-12B
 Submitted May 28, 2018
 CIK File No. 0001727263

Dear Ms. McManus:

On behalf of our client, frontdoor, inc., formerly known as AHS Holding Company, Inc. (“Frontdoor” or the “Company”), which is currently a wholly owned subsidiary of ServiceMaster Global Holdings, Inc. (“ServiceMaster”), this letter responds to certain oral comments from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) that were conveyed telephonically on June 11, 2018 with respect to Amendment No. 2 to the Company’s Draft Registration Statement on Form 10, confidentially submitted to the Commission on May 28, 2018 (the “Registration Statement”).

We note that, in connection with this letter, we are publicly filing a Registration Statement on Form 10 (the “Public Filing”) electronically via the EDGAR system on the date hereof.  Additionally, we are separately furnishing to the Staff a hard copy of this letter, along with four copies of the Public Filing marked to show the changes made to the Registration Statement.

For the Staff’s convenience, the text of the Staff’s comment is set forth below in bold, followed by the Company’s response.  Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Public Filing.  All page references in the responses set forth below refer to pages of the Public Filing.

Form 10

Exhibit Index, page iv

1.              Please file all exhibits prior to effectiveness of the Registration Statement, including the employment agreement mentioned in the Registration Statement.

Response:  In response to the Staff’s comment, we respectfully inform the Staff that the Company has included the Employment Agreement, dated as of May 15, 2018, between Rexford J. Tibbens and American Home Shield as Exhibit 10.3 to the Public Filing, and will include any additional exhibits prior to requesting effectiveness of the Registration Statement.

Exhibit 99.1

Description of Our Capital Stock

Exclusive Forum, page 148

2.              Please revise Exhibit 99.1 of the Registration Statement to disclose the reasons why management adopted the exclusive forum provision contained in your certificate of incorporation.

Response:  In response to the Staff’s comment, page 148 and 149 of the Public Filing has been revised.

Notes to Unaudited Pro Forma Combined Financial Statements, page 71

3.              Please revise Note D in the Notes to Unaudited Pro Forma Consolidated Financial Statements section to disclose the amount of proceeds from new indebtedness that will be retained by ServiceMaster after the separation.

Response:  In response to the Staff’s comment, page 71 of the Public Filing has been revised.

*                                         *                                         *                                         *                                         *                                         *

2

If you have any questions concerning the Public Filing or require any additional information in connection with the filing, please do not hesitate to contact the undersigned at (212) 403-1233.

Sincerely yours,

/s/ Andrew R.   Brownstein

Andrew R. Brownstein

cc:                                Rexford J. Tibbens, Chief Executive Officer, frontdoor, inc.

Dirk Gardner, Vice President, Associate General Counsel — Corporate & Assistant Secretary, ServiceMaster Global Holdings, Inc.

April  10, 2018

Via E -mail
Nikhel Varty, Chief Executive Officer
American Holding Company Inc.
c/o ServiceMaster Global Holdings, Inc.
150 Peabody  Place
Memphis, TN 381 03

Re: American Holding Company, Inc.
Amendment No. 1 to  Draft Registration Statement on Form 10 -12B
Submitted March 30, 2018
CIK No. File No. 0001727263

Dear Mr. Varty:

We have reviewed your amended draft registration statement  and have the following
comment.  In our comment, we may ask you to provide us w ith information so we may better
understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If yo u do not believe our comment  applies  to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to this comment  and your
amended draft regis tration statement or filed registration statement,  we may have  additional
comments.

Description of Our Capital Stock

Exclusive Forum, page 122

1. Please explain the reasons why management adopted the exclusive forum provision
contained in your certificate of incorporation.

Nikhel Varty
American Holding Company Inc.
April 10, 2018
Page 2

 You may contact Becky Chow at (202)551 -6524 or Kristi Marrone at (202)551 -3429 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Stacie Gorman at (202)551 -3585 or me  at (202)551 -3215 with any other questions.

Sincerely,

 /s/ Kim McManus

 Kim McManus
Senior Counsel
Office of Real Estate and
Commodities

cc: Andrew R. Brownstein, Esq. ( via e -mail)

Mail Stop 3233
February 16, 2018

Via E -mail
Nikhel Varty, Chief Executive Officer
ServiceMaster Global Holdings, Inc.
860 Ridge Lake Blvd.
Memphis, TN 38120

Re: American Holding Company, Inc.
 Draft Registration Statement on Form 10 -12B
Submitted  January 23, 2018
CIK No. File No. 0001727263

Dear Mr. Varty:

We have reviewed your draft registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

Form 10

Exhibit Index

1. You currently identify a number of “form of” agreements.  Please tell us if you will
execute any of these agreements before effectiveness of the Form 10.

Nikhel Varty, Chief Executive Officer
ServiceMaster Global Holdings,  Inc.
February 16, 2018
Page 2

 Exhibit 99.1

Questions and Answers about the Separation and Distribution, page 1

How will ServiceMaster vote any shares of AHS . . .?, page 8

2. We note your expectation that ServiceMaster will agree to vote any shares of AHS it
retains in proportion to the votes cast by your other stockholders.  Please to clarify if
ServiceMaster “will” agree to vote its AHS shares, rather than cha racterizing this as a
forward -looking expectation.

Risk Factors

If the distribution, together with certain related transactions, does not qualify as a transaction that
is generally tax -free . . ., page 34

3. To the extent practicable,  please quantify the range of potential tax liability you and
ServiceMaster could incur in the event the IRS were to prevail in a challenge regarding
the tax -free treatment of the transaction.

The Separation and Distribution
Incurrence of Debt, page 50

4. We note your disclosure regarding the amount to be available under your revolving credit
facility and the amount of principal to be borrowed on your term facilities.   To the extent
that significant terms of the new debt are known, please provide them.   Include interest
rates, maturity dates, collateral requirements (if any), and any other known material
terms.

Business, page 63

5. We note your disclosure on page 32  that your business is subject to non -solicitation and
no-hire covenants.  Please provide more detailed disclosure in this section regarding these
restrictions and the potential impact on your opportunities to expand your business.

Note 3.   Significant A ccounting Policies
Restricted Net Assets, Page F -10

6. We note the third party restrictions on the ability of certain of your subsidiaries to
transfer funds to you in the amount of $151 million as of December 31, 2016.   Please
advise us how you considered th e disclosure requirements of Rule 4 -08(e) and Rule 5 -04,
Schedule I of Regulation S -X.

Nikhel Varty, Chief Executive Officer
ServiceMaster Global Holdings,  Inc.
February 16, 2018
Page 3

You may contact Becky Chow at (202)  551-6524 or Kristi Marrone at (202)  551-3429 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Stacie Gorman at (202)  551-3585 or me at (202)  551-3215 with any other questions.

Sincerely,

/s/ Kim McManus

 Kim McManus
Senior Counsel
Office of Real Estate and
Commodities

cc: Andrew R. Brownstein, Esq. ( via e -mail)