February 3, 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 limited our review of your filing to the financial statements
and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your

       After reviewing your response to these comments, we may have additional

Form 10-K for the Fiscal Year Ended July 31, 2019

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 41

1.    Please expand your results of operations discussion to quantify the
impact of each factor
      identified as causing changes in results between periods. For example, we
note that
      Mountain Reported EBITDA increased as a result of strong North American
pass sales
      growth, strong growth in visitation and spending at western U.S. resorts,
and recent
      acquisitions. Please quantify the impact of each factor attributing to
the increase, here,
      and throughout your discussion, in accordance with Item 303(a)(3)(iii) of
Regulation S-K
      and Section III.D of SEC Release No. 33-6835.
Reconciliation of Segment Earnings, page 49

2.    Please revise your presentations of non-GAAP measures to begin
reconciliations with
      GAAP results rather than non-GAAP results. See Question 102.10 of the
 Michael Z. Barkin
Vail Resorts, Inc.
February 3, 2020
Page 2
         & Disclosure Interpretations on The Use of Non-GAAP Financial
Measures. Please note
         that this comment also applies to your Form 10-Q and earnings
Contractual Obligations, page 54

3.       We note that the line item "Purchase Obligations and Other" in the
Table of Contractual
         Obligations includes amounts for trade payables, accrued payroll and
benefits, accrued
         fees and assessments, contingent consideration liability, and accrued
taxes, which
         are already included on the balance sheet. Please tell us why you
believe these items meet
         the criteria in Item 303(a)(5)(ii)(D) of Regulation S-K to be included
in the table.

       In closing, 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.

       You may contact Amy Geddes at 202-551-3304 or Theresa Brillant at
202-551-3307 with
any questions.

FirstName LastNameMichael Z. Barkin                          Sincerely,
Comapany NameVail Resorts, Inc.
                                                             Division of
Corporation Finance
February 3, 2020 Page 2                                      Office of Trade &
FirstName LastName