March 14, 2019

Todd H. Siegel
Chief Executive Officer
Affinion Group Holdings, Inc.
6 High Ridge Park
Stamford, CT 06905

       Re: Affinion Group Holdings, Inc.
           Preliminary Information Statement on Form 14C
           Filed March 5, 2019
           File No. 000-55577

Dear Mr. Siegel:

       We have reviewed your filing and have the following comment. Please
respond to our
comment 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 comment applies to
your facts and
circumstances, please tell us why in your response.

       After reviewing your response, we may have additional comments.

Preliminary Information Statement on Form 14C

Action By Written Consent: Approval of Related Party Transactions, page 3

1.    You disclose in this section that you have received the required written
consents to allow
      holders of five percent or more of your outstanding common stock to
participate in certain
      related party transactions. Because those related party transactions
involve the exchange
      of existing notes for common stock and warrants, and the issuance of new
notes, please
      revise your preliminary information statement to provide all the
disclosure required by
      Items 11 and 12 of Schedule 14A, including the disclosure under Item
13(a) of Schedule
      14A. Refer to Item 1 of Schedule 14C and Note A of Schedule 14A.
Alternatively,
      explain why such disclosure is not required in this information
statement.
        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.
 Todd H. Siegel
Affinion Group Holdings, Inc.
March 14, 2019
Page 2

       Please contact Michael C. Foland, Staff Attorney, at (202) 551-6711 or
Matthew
Crispino, Staff Attorney, at (202) 551-3456 with any questions.



                                                          Sincerely,
FirstName LastNameTodd H. Siegel
                                                          Division of
Corporation Finance
Comapany NameAffinion Group Holdings, Inc.
                                                          Office of Information
Technologies
March 14, 2019 Page 2                                     and Services
FirstName LastName