CONFIDENTIAL

FOR COMMISSION USE ONLY

MARRIOTT OWNERSHIP RESORTS, INC.

ILG, LLC

6649 Westwood Blvd.

Orlando, Florida 32821

May 23, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

(SEC File No. 333-231300) Originally Filed on May 8, 2019

Ladies and Gentlemen:

Reference is made to the Registration Statement on Form S-4 (File No. 333-231300) (the “Registration Statement”) of Marriott Ownership Resorts, Inc., a Delaware corporation, ILG, LLC, a Delaware limited liability company, and each of the guarantor entities listed on Schedule A hereto (collectively, the “Registrants”), registering the offers to exchange up to $88,165,000 aggregate principal amount of 5.625% Senior Notes due 2023 and $750,000,000 aggregate principal amount of 6.500% Senior Notes due 2026 (collectively with the respective guarantees thereof, the “Exchange Notes”) for like aggregate principal amounts of 5.625% Senior Notes due 2023 and 6.500% Senior Notes due 2026 (collectively with the respective guarantees thereof, the “Outstanding Notes”), respectively.

Please be advised that the Registrants are registering the exchange offers in reliance on the position of the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) enunciated in: Exxon Capital Holdings Corporation, SEC No-Action Letter (available May 13, 1988); Morgan Stanley & Co. Inc., SEC No-Action Letter (available June 5, 1991); and Shearman & Sterling, SEC No-Action Letter (available July 2, 1993). In addition, the Registrants hereby represent that they have not entered into any arrangement or understanding with any person to distribute the Exchange Notes to be received in the exchange offers and, to the best of the Registrants’ information and belief, each person participating in the exchange offers will be acquiring the Exchange Notes in its ordinary course of business and will not have any arrangement or understanding with any person to participate in the distribution of the Exchange Notes to be received in the exchange offers. In this regard, the Registrants will make each person participating in any of the exchange offers aware, by means of the prospectus relating to the exchange offers (the “Exchange Offer Prospectus”) and the related letter of instruction, that if such person is participating in an exchange offer for the purpose of distributing the applicable series of Exchange Notes to be acquired in an exchange offer, such person (i) cannot rely on the Staff position enunciated in Exxon Capital Holdings Corporation or interpretative letters to similar effect and (ii) must comply with the registration and prospectus delivery requirements of the Securities Act of 1933, as amended (the “Securities Act”), in connection with a secondary resale transaction. The Registrants acknowledge that such a secondary resale transaction by such person participating in an exchange offer for the purpose of distributing the applicable series of Exchange Notes should be covered by an effective registration statement containing the selling security holder information required by Item 507 of Regulation S-K under the Securities Act.

The Registrants represent that with respect to any broker-dealer that participates in the exchange offers with respect to Outstanding Notes acquired for its own account as a result of market-making activities or trading activities each such broker-dealer must confirm that it has not entered into any arrangement or understanding with the Registrants or an affiliate of the Registrants to distribute the Exchange Notes. In addition, the Registrants will include in the letter of instruction to be executed by an exchange offeree in order to participate in the applicable exchange offer the following additional provisions, in substantially the form set forth below:

If you have any questions or comments or desire further information in respect of the Registration Statement, please do not hesitate to contact Richard B. Aftanas of Kirkland & Ellis LLP, counsel to the Registrants, at (212) 446-4722.

Kirkland & Ellis LLP

Schedule A

Aqua Hospitality LLC

Aqua Hotels & Resorts, LLC

Aqua Hotels and Resorts Operator LLC

Aqua Hotels and Resorts, Inc.

Aqua Luana Operator LLC

Aqua-Aston Holdings, Inc.

Aqua-Aston Hospitality, LLC

Aston Hotels & Resorts Florida, LLC

Beach House Development Partnership

CDP GP, Inc.

CDP Investors, L.P.

Cerromar Development Partners GP, Inc.

Cerromar Development Partners, L.P., S.E.

Coconut Plantation Partner, Inc.

Data Marketing Associates East, Inc.

Diamond Head Management LLC

Flex Collection, LLC

FOH Holdings, LLC

FOH Hospitality, LLC

Grand Aspen Holdings, LLC

Grand Aspen Lodging, LLC

Hawaii Vacation Title Services, Inc.

Hotel Management Services LLC

HPC Developer, LLC

HT-Highlands, Inc.

HTS-BC, L.L.C.

HTS-Beach House Partner, L.L.C.

HTS-Beach House, Inc.

HTS-Coconut Point, Inc.

HTS-Ground Lake Tahoe, Inc.

HTS-Key West, Inc.

HTS-KW, Inc.

HTS-Lake Tahoe, Inc.

HTS-Loan Servicing, Inc.

HTS-Main Street Station, Inc.

HTS-Maui, L.L.C.

HTS-San Antonio, Inc.

HTS-San Antonio, L.L.C.

HTS-San Antonio, L.P.

HTS-Sedona, Inc.

HTS-Sunset Harbor Partner, L.L.C.

HTS-Windward Pointe Partner, L.L.C.

HV Global Group, Inc.

HV Global Management Corporation

HV Global Marketing Corporation

HVO Key West Holdings, LLC

IIC Holdings, Incorporated

ILG Management, LLC

ILG Shared Ownership, Inc.

Interval Acquisition Corp.

Interval Holdings, Inc.

Interval International, Inc.

Interval Resort & Financial Services, Inc.

Interval Software Services, LLC

Kai Management Services LLC

Kauai Blue, Inc.

Kauai Lagoons Holdings LLC

Key Wester Limited

Lagunamar Cancun Mexico, Inc.

Management Acquisition Holdings, LLC

Marriott Kauai Ownership Resorts, Inc.

Marriott Ownership Resorts Procurement, LLC

Marriott Resorts Hospitality Corporation

Marriott Resorts Sales Company, Inc.

Marriott Vacations Worldwide Corporation

Maui Condo and Home, LLC

MH Kapalua Venture, LLC

MORI Golf (Kauai), LLC

MORI Member (Kauai), LLC

MORI Residences, Inc.

MORI Waikoloa Holding Company, LLC

MTSC, Inc.

MVW of Hawaii, Inc.

MVW SSC, Inc.

MVW US Holdings, Inc.

MVW US Services, LLC

Pelican Landing Timeshare Ventures Limited Partnership

R.C. Chronicle Building, L.P.

RBF, LLC

RCC (GP) Holdings LLC

RCC (LP) Holdings L.P.

RCDC 942, L.L.C.

RCDC Chronicle LLC

REP Holdings, Ltd.

Resort Management Finance Services, Inc.

Resort Sales Services, Inc.

RQI Holdings, LLC

S.O.I. Acquisition Corp.

Scottsdale Residence Club, Inc.

Sheraton Flex Vacations, LLC

St. Regis New York Management, Inc.

St. Regis Residence Club, New York Inc.

The Cobalt Travel Company, LLC

The Lion & Crown Travel Co., LLC

The Ritz-Carlton Development Company, Inc.

The Ritz-Carlton Management Company, L.L.C.

The Ritz-Carlton Sales Company, Inc.

The Ritz-Carlton Title Company, Inc.

Vacation Ownership Lending GP, Inc.

Vacation Ownership Lending, L.P.

Vacation Title Services, Inc.

VCH Communications, Inc.

VCH Consulting, Inc.

VCH Systems, Inc.

Vistana Acceptance Corp.

Vistana Aventuras, Inc.

Vistana Development, Inc.

Vistana Hawaii Management, Inc.

Vistana Management, Inc.

Vistana MB Management, Inc.

Vistana Portfolio Services, Inc.

Vistana PSL, Inc.

Vistana Residential Management, Inc.

Vistana Signature Experiences, Inc.

Vistana Signature Network, Inc.

Vistana Vacation Ownership, Inc.

Vistana Vacation Realty, Inc.

Vistana Vacation Services Hawaii, Inc.

VOL GP, Inc.

VOL Investors, L.P.

Volt Merger Sub, LLC

VSE Development, Inc.

VSE East, Inc.

VSE Mexico Portfolio Services, Inc.

VSE Myrtle Beach, LLC

VSE Pacific, Inc.

VSE Trademark, Inc.

VSE Vistana Villages, Inc.

VSE West, Inc.

Westin Sheraton Vacation Services, Inc.

Windward Pointe II, L.L.C.

Worldwide Vacation & Travel, Inc.

WVC Rancho Mirage, Inc.