February 13, 2020 Michael Z. Barkin Executive Vice President and Chief Financial Officer Vail Resorts, Inc. 390 Interlocken Crescent Broomfield, Colorado 80021 Re: Vail Resorts, Inc. Form 10-K for the Fiscal Year Ended July 31, 2019 Filed September 26, 2019 File No. 001-09614 Dear Mr. Barkin: We have completed our review of your filing. 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