May 22, 2019 Michael Chan Chief Financial Officer TEXTAINER GROUP HOLDINGS LTD 16 Par-La-Ville Road Hamilton HM 08 Bermuda Re: TEXTAINER GROUP HOLDINGS LTD Form 20-F for the Fiscal Year Ended December 31, 2018 Filed March 25, 2019 File No: 1-33725 Dear Mr. Chan: 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 Manufacturing and Construction