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                              December 10, 2021

       Bryant Kirkland
       Chief Financial Officer
       Douglas Elliman Inc.
       4400 Biscayne Boulevard
       Miami, FL 33137

                                                        Re: Douglas Elliman
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed December 7,
2021
                                                            File No. 333-261523

       Dear Mr. Kirkland:

              We have reviewed your registration statement and have the
following comment. In our
       comment, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to our comment, we may have additional comments.

       Registration Statement on Form S-1 filed December 7, 2021

       Material Federal Income Tax Consequences, page 14

   1.                                                   We note disclosures
here and throughout the prospectus that the number of shares of
                                                        Spinco common stock
distributed in respect of shares of Vector common stock underlying
                                                        Vector stock option
awards and restricted stock awards "will be reduced in satisfaction of
                                                        such holders    tax
obligations." Please revise to explain how the amount of this reduction
                                                        will be determined and
how this will satisfy a holder's tax obligations. Please also revise
                                                        to state that you have
received counsel's opinion and file a signed tax opinion as an exhibit
                                                        to the registration
statement prior to effectiveness.
 Bryant Kirkland
Douglas Elliman Inc.
December 10, 2021
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Wilson Lee at 202-551-3468 or Babette Cooper at
202-551-3396 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Patrick Costello at 202-551-8742 or Pam Long at 202-551-3765 with any
other
questions.



                                                           Sincerely,
FirstName LastNameBryant Kirkland
                                                           Division of
Corporation Finance
Comapany NameDouglas Elliman Inc.
                                                           Office of Real
Estate & Construction
December 10, 2021 Page 2
cc:       Robert Downes, Esq.
FirstName LastName