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August
24, 2007
Mr.
Michael Fay
Securities
and Exchange Commission
Division
of Corporation Finance
Mail
Stop
3561
Washington,
DC 20549
Re:
Vail Resorts, Inc.
File
No. 001-09614
Form
10-K: For the Fiscal Year Ended July 31, 2006
Dear
Mr.
Fay:
Pursuant
to your letter dated May 11, 2007 and follow-up telephone conversations
conducted between the Securities and Exchange Commission (the “Commission”)
staff (the “Staff”) and Vail Resorts, Inc. (the “Company”) this letter provides
notice herewith that the Company has filed amendments to its Annual Report
on
Form 10-K for the year ended July 31, 2006 and its Quarterly Reports on Form
10-Q for the quarters ended October 31, 2006, January 31, 2007 and April 30,
2007. These amendments restate the Company’s Consolidated Statements
of Cash Flows by reclassifying cash outflows related to its investments in
real
estate, disclosed as a separate line item, from investing activities to
operating activities. Additionally, the Company filed a Form 8-K
indicating that its previously filed Annual Report on Form 10-K for the year
ended July 31, 2006 and its Quarterly Reports on Form 10-Q for the quarters
ended October 31, 2006, January 31, 2007 and April 30, 2007 should no longer
be
relied upon.
As
requested by the Staff, we are providing the following
acknowledgements:
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the
Company is responsible for the adequacy and accuracy of the disclosures
in
its filings; and
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·
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Staff
comments or changes to disclosures in response to Staff comments
do not
foreclose the Commission from taking any action with respect to the
filing; and
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·
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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.
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If
you
have any further questions or require additional information, please do not
hesitate to contact me at 303-404-1802.
Sincerely,
/s/
Jeffrey W. Jones
Jeffrey
W. Jones
Senior
Executive Vice President and
Chief
Financial Officer