Wyndham Worldwide Corporation

7 Sylvan Way

Parsippany, New Jersey 07054

June 15, 2006

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-4561

 

Attn:   Michael McTiernan, Esq.
     Special Counsel

 

  RE: Wyndham Worldwide Corporation

Registration Statement on Form 10

Commission File No. 001-32876

Dear Mr. McTiernan:

In connection with the above referenced Registration Statement on Form 10, as amended (the “Filing”), of Wyndham Worldwide Corporation (the “Company”), the undersigned hereby acknowledges on behalf of the Company:

 

  (i) the Company is responsible for the adequacy and accuracy of the disclosure in the Filing;

 

  (ii) staff comments or changes to disclosure in response to staff comments do not foreclose the Securities and Exchange Commission (the “Commission”) from taking any action with respect to the Filing; and

 

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  (iii) 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.

 

Very truly yours,

WYNDHAM WORLDWIDE CORPORATION

By:  

/s/ Virginia M. Wilson

 

Name:

 

Virginia M. Wilson

 

Title:

 

Executive Vice President and

Chief Financial Officer

 

cc: Geoffrey Ossias
   Matthew Maulbeck
   Josh Forgione
   Eric J. Bock
   Scott G. McLester

 

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