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                             March 24, 2021

       Douglas E. Barnett
       Chief Financial Officer
       Sabre Corp
       3150 Sabre Drive
       Southlake, TX 76092

                                                        Re: Sabre Corp
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 25,
2021
                                                            8-K filed February
16, 2021
                                                            File No. 001-36422

       Dear Mr. Barnett:

               We have reviewed your January 15, 2021 response to our comment
letter 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. Unless we note otherwise, our references to prior
comments are to
       comments in our December 10, 2020 letter.

       Form 10-K for the Year Ended December 31, 2020

       Item 6. Selected Financial Data
       Non-GAAP Financial Measures, page 27

   1.                                                   We note your response
to prior comment six. It remains unclear to us why it would be
                                                        appropriate to
calculate Adjusted EBITDA by excluding the amortization of
                                                        upfront incentive
consideration which is tied to booking volumes and is incurred to obtain
                                                        contracts with
customers. Please advise or revise.
       Components of Revenues and Expenses
       Technology Costs, page 37

   2.                                                   We note your response
to comment one that research and development costs, "were and
                                                        are expected to
continue to be de minimis due to the nature of the Company's business and
                                                        its products and
therefore are immaterial for separate disclosure." However, we note your
 Douglas E. Barnett
Sabre Corp
March 24, 2021
Page 2
         "Growth Strategy" on page 2 discloses a strategy of (d)eveloping
innovative technology
         products through investment of significant resources in
next-generation technology
         solutions and under "Technology" you disclose "We invest heavily in
software
         development...". In addition, on page 8 within Risk Factors you
disclose "highly
         competitive evolving markets" and your need to "innovate and evolve."
Please tell us why
         in view of these disclosures research and development costs are
quantitatively de minimis
         in amount. Please advise or revise and if material, please disclose
which line item of the
         Statement of Comprehensive Loss (Income) research and development
costs are included.

Form 8-K filed February 16, 2021

Exhibit 99.1
Tabular Reconciliations for Non-GAAP Measures, page 17

3.       Please disclose the respective comparable ratio for Adjusted EBITDA
margin calculated
         using GAAP amounts. Additionally, disclose how Net Debt / LTM Adjusted
EBITDA is
         calculated and why it is useful information to investors. Refer to
Items 10(e)1(i)(B) and
         (C) of Regulation S-K and footnote 27 of non-GAAP adopting Release No.
33-8176.
        You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or Craig
Wilson, Senior Adviser at (202) 551-3226 if you have questions regarding
comments on the
financial statements and related matters.



FirstName LastNameDouglas E. Barnett                          Sincerely,
Comapany NameSabre Corp
                                                              Division of
Corporation Finance
March 24, 2021 Page 2                                         Office of
Technology
FirstName LastName