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                                                            October 24, 2024

Jonathan R. Root
Chief Financial Officer
Harley-Davidson, Inc.
3700 West Juneau Avenue
Milwaukee, WI 53208

       Re: Harley-Davidson, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Filed February 23, 2024
           File No. 001-09183
Dear Jonathan R. Root:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Annual Report on Form 10-K for the Fiscal year Ended December 31, 2023
Note 19. Supplemental Consolidating Data, page 108

1.     Please tell us why you have not provided supplemental consolidating data
       of statements of income and cash flows for each year in which audited
financial
       statements are presented. In this regard, we note you have provided
supplemental
       consolidating data for the years ended December 31, 2023 and 2022,
rather than also
       providing for the earliest year of 2021. Please advise or revise.


        In closing, 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 Beverly Singleton at 202-551-3328 or Melissa Gilmore at
202-551-
3777 with any questions.
 October 24, 2024
Page 2



                   Sincerely,

                   Division of Corporation Finance
                   Office of Manufacturing
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