United States securities and exchange commission logo March 21, 2024 Karen Haller President and Chief Executive Officer Southwest Gas Holdings, Inc. 8360 S. Durango Drive Las Vegas, NV 89113 Re: Southwest Gas Holdings, Inc. Preliminary Proxy Statement on Schedule 14A Filed March 8, 2024 File No. 001-37976 Dear Karen Haller: We have reviewed your filing and have the following comment. 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. Preliminary Proxy Statement on Schedule 14A Approval of the Company's Tax-Free Spin Protection Plan, page 83 1. Please revise your disclosure to state the general effect of the Tax-Free Spin Protection Plan. Refer to Item 19 of Schedule 14A, including Instruction 2 to such item. For example, we note your disclosure in your current report on Form 8-K filed on November 6, 2023 that the Rights may have certain anti-takeover effects, and your disclosure in such current report that the Plan works by imposing a significant penalty upon any person or group of affiliated or associated persons that acquires a certain percentage or more of the outstanding common stock, except in certain situations specified in the Plan. 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. Karen Haller Southwest Gas Holdings, Inc. March 21, 2024 Page 2 Please contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584 with any questions. Sincerely, FirstName LastNameKaren Haller Division of Corporation Finance Comapany NameSouthwest Gas Holdings, Inc. Office of Energy & Transportation March 21, 2024 Page 2 cc: John Hensley FirstName LastName