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                             March 22, 2022

       Jennifer F. Scanlon
       President and Chief Executive Officer
       UL Inc.
       333 Pfingsten Road
       Northbrook, Illinois 60062

                                                        Re: UL Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted March 9,
2022
                                                            CIK No. 0001901440

       Dear Ms. Scanlon:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted
March 9, 2022

       Market and Industry Data, page 2

   1.                                                   We note your response
to our prior comment 3 regarding sources that had already taken
                                                        into account the
COVID-19 pandemic. Where you rely on sources that do not take into
                                                        account the impact of
the COVID-19 pandemic in your filing, please disclose that you are
                                                        relying on such sources
in each case.
   2.                                                   We note your response
to comment 6, and your amended disclosure that "In May 2021,
                                                        we commissioned a
market analysis report, which analyzes the size, competitive
                                                        landscape and growth
trajectory of the markets in which we operate, as well as other
                                                        general trends in our
industry. Where we attribute information to 'a leading global
                                                        consulting firm'
throughout this prospectus, such references are to the market analysis
 Jennifer F. Scanlon
UL Inc.
March 22, 2022
Page 2
      report." We also note your response that you are not permitted to name
the third-party
      consulting firm that prepared the report in a public filing, but we are
not persuaded by
      your response. Please identify the consulting firm, and file the consent
of the consulting
      firm as an exhibit to your registration statement. See Section 7 and Rule
436 of the
      Securities Act. Alternatively, please remove data from the report from
the disclosure in
      your filing.
Post-Employment Provisions, page 149

3.    You disclose that "[t]he Company entered into a post-termination
consulting arrangement
      with Mr. Jesudas, which will commence upon his retirement." Please file
the agreement
      as an exhibit to your registration statement. Alternatively, please tell
us why you believe
      you are not required to do so.
       Please contact Taylor Beech at 202-551-4515 or Katherine Bagley at
202-551-2545 with
any questions.



                                                            Sincerely,
FirstName LastNameJennifer F. Scanlon
                                                            Division of
Corporation Finance
Comapany NameUL Inc.
                                                            Office of Trade &
Services
March 22, 2022 Page 2
cc:       Cathy A. Birkeland, Esq.
FirstName LastName