United States securities and exchange commission logo August 21, 2020 David W. Hult President and Chief Executive Officer Asbury Automotive Group, Inc. 2905 Premiere Parkway NW, Suite 300 Duluth, GA 30097 Re: Asbury Automotive Group, Inc. Registration Statement on Form S-4 Filed August 14, 2020 File No. 333-246335 Dear Mr. Hult: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Cara Wirth at (202) 551-7127 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Joel T. May, Esq.