United States securities and exchange commission logo May 15, 2020 Paul Seavey Executive Vice President and Chief Financial Officer Equity Lifestyle Properties, Inc. Two North Riverside Plaza Suite 800 Chicago, IL 60606 Re: Equity Lifestyle Properties, Inc. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 24, 2020 File No. 001-11718 Dear Mr. Seavey: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Real Estate & Construction