Mail Stop 3561
                                                           September 4, 2018


Mr. Thomas F. Wolfe
Chief Financial Officer and Secretary
Camping World Holdings, Inc.
250 Parkway Drive, Suite 270
Lincolnshire, IL 60069

       Re:    Camping World Holdings, Inc.
              Form 10-K for the Fiscal Year Ended December 31, 2017
              Filed March 13, 2018
              Form 10-Q for the Quarterly Period Ended June 30, 2018
              Filed August 9, 2018
              File No. 1-37908

Dear Mr. Wolfe:

        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
response.

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

Form 10-K for the Fiscal Year Ended December 31, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations

Non-GAAP Financial Measures, page 95

   1. We note your presentation of Adjusted EBITDA, which includes an
adjustment for pre-
      opening store costs related to your Gander Mountain acquisition. Please
tell us in more
      detail, and revise future filings to better explain to your investors,
what comprises this
      adjustment and why you believe this adjustment is appropriate. As part of
your response,
      please tell us how you considered whether these are normal, recurring,
cash operating
      expenses and for how many periods you expect to make similar adjustments.
Also tell us
      the number of Gander Mountain stores to which this adjustment relates, as
this appears to
      be a relatively large expense amount in light of your disclosure on page
11 that as of
 Mr. Thomas F. Wolfe
Camping World Holdings, Inc.
September 4, 2018
Page 2

       December 31, 2017 you only operated two Gander Outdoors stores. In your
response,
       please also apply this comment to your June 30, 2018 Form 10-Q.

   2. We note your presentation of adjusted pro forma net income and adjusted
pro forma
      earnings per fully exchanged and diluted share, which in part adjusts for
the reallocation
      of income attributable to non-controlling interests from the assumed
exchange of all
      outstanding common units in CWGS, LLC for shares of Class A common stock
and the
      related impact on the number of Class A common shares outstanding. Please
tell us why
      you believe it is meaningful and appropriate to assume the exchange of
the CWGS, LLC
      common units and related Class B shares in periods when such exchange is
antidilutive.
      As part of your response, please tell us whether you have had any
conversations with the
      CWGS, LLC common unitholders that would indicate that this exchange is
imminent or
      received any other indication that the common unitholders are likely to
make an
      uneconomic decision when deciding whether and when to exchange the common
units
      for Class A shares.

   3. We note your presentation of adjusted pro forma net income and adjusted
pro forma
      earnings per fully exchanged and diluted share. Please tell us why you
believe it is
      appropriate to characterize these measures as "pro forma" and how your
presentation of
      these pro forma metrics complies with Article 11 of Regulation S-X. Your
response
      should include, but not be limited to, telling us why you believe
presenting this metric for
      five years is appropriate, particularly since your current capital
structure did not exist in
      most of those periods.

Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

10. Income Taxes, page 142

   4. We note your October 6, 2016 Tax Receivable Agreement that provides for
the payment
      to the Continuing Equity Owners and Crestview Partners II GP, L.P of 85%
of the
      amount of tax benefits. We also note the Tax Receivable Agreement
liability recorded on
      the balance sheet, the $99.7 million re-measurement gain on the income
statement and
      the establishment of the liability and related changes recorded through
additional paid in
      capital. Please tell us in more detail how you are accounting for the Tax
Receivable
      Agreement, including your basis in GAAP. In doing so, please tell us
which transactions
      are recorded through equity and which are reflected in the income
statement and why the
      difference in how the transactions are recorded is appropriate. Also,
please provide us
      with a rollfoward of this liability balance from December 31, 2016
through June 30, 2018
      and explain the significant activity.
 Mr. Thomas F. Wolfe
Camping World Holdings, Inc.
September 4, 2018
Page 3

14. Acquisition, pages 150

   5. Please disclose the pro forma information required by ASC
805-10-50-2(h)(3) for your
      material acquisitions or state that disclosure of such information is
impracticable and why
      it is impracticable.

   6. We note you recorded significant goodwill from your 2017 acquisitions. As
required by
      ASC 805-30-50-1(a), please disclose a qualitative description of the
factors that make up
      the goodwill recognized, and tell us this information in your response.

Form 10-Q for the Quarterly Period Ended June 30, 2018

Financial Statements

Notes to Consolidated Financial Statements

17. Earnings Per Share, page 30

   7. Please tell us the underlying factors that change from period to period
and cause the
      exchange of CWGS, LLC common units into Class A shares to be dilutive in
some
      periods and anti-dilutive in other periods. Your response should include
but not be
      limited to explaining the changes between the year ended December 31,
2017 where the
      exchange of common units into Class A shares was anti-dilutive and the
six months
      ended June 30, 2018 where the exchange of common units into Class A
shares was
      dilutive. Your response should also explain how you determine what
portion of total net
      income attributable to non-controlling interests you will add back when
assuming the
      exchange of common units into Class A shares, and illustrate your
calculation for the six
      months ended June 30, 2018.

        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 Yong Kim, Staff Accountant, at (202) 551-3323 or me at
(202) 551-
3737 with any questions.

                                                           Sincerely,

                                                           /s/ Jennifer
Thompson

                                                           Jennifer Thompson
                                                           Accounting Branch
Chief
                                                           Office of Consumer
Products