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      Sonesta International Hotels Corporation Correspondence to the SEC 12/13/2005

    VIA
      FACSIMILE: (202) 772-9210

    December
      13, 2005

    Mr.
      Daniel L. Gordon

    Branch
      Chief

    Securities
      and Exchange Commission

    Division
      of Corporate Finance

    100
      F
      Street, NE

    Washington,
      DC 20549

    Mr.
      Eric
      C. McPhee

    Staff
      Accountant

    Securities
      and Exchange Commission

    Division
      of Corporate Finance

    100
      F
      Street, NE

    Washington,
      DC 20549

    Re:
       Sonesta
      Beach Resort Key Biscayne

    Dear
      Mr.
      Gordon and Mr. McPhee,

    I
      have
      received you letter of November 21, 2005, and I appreciated the time Mr. McPhee
      took to discuss and clarify the comments during our telephone conversation
      on
      December 2, 2005. The answers below are in the same sequence as the comments
      in
      your letter.

            1.

              Remaining
                basis in current hotel
                assets.

    Even
      though Sonesta has a continuing interest in the new condo hotel to be created,
      it did sell the existing hotel, rather than abandon it. At the closing in April
      2005, Sonesta received $60 million in non-refundable proceeds. Because the
      development process will take time, the parties to this transaction agreed
      Sonesta could continue to operate the hotel until such time that the
      construction of the new hotel could begin. If Sonesta would have made the same
      exact deal but closed the hotel right after the transfer/sale, it is obvious
      that the remaining basis in the assets (currently approximately $30 million)
      should have reduced the $ 60 million proceeds received in April 2005. While
      there is still uncertainty regarding the entire project moving forward, we
      will
      continue to operate the hotel and depreciate the assets over their original
      estimated lives. Once we have sufficient sales of condos to secure construction
      financing, and the project is certain to move ahead, we will remove the
      remaining basis from our assets, and reduce the finance liability recorded
      on
      our balance sheet.

    Mr.
      Daniel L. Gordon

    Mr.
      Eric
      C. McPhee

    Securities
      and Exchange Commission

    December
      13, 2005

    Page
      2

            2.

              Fair
                value of assets
                transferred.

    Sonesta’s
      position is that even though our continuing interest in the development
      partnership is in the form of a 50% equity interest in the partnership,
      Sonesta’s economic interest is a profit participation in a new value to be
      created in the new condominium hotel project by our partner, Fortune
      International. As such, Sonesta values its interest based on the (non
      refundable) proceeds of approximately $60 million received in April 2005. Even
      though we participate in certain major decisions, we are a limited partner,
      and
      Fortune, as general partner, is responsible for making this project a success.
      Any and all additional proceeds to Sonesta are dependent on a number of
      variables in the development process, including approval of designs of the
      building(s), sufficient sales of condominium units at prices sufficient to
      cover
      all costs, the ability to secure financing and the ability to bring in the
      development at a certain cost. All
      of these
      variables are uncertain, and out of Sonesta’s control. Therefore, we intend to
      recognize any additional value in excess of the $60 million received only when
      realized in cash.

    I
      am
      available to further discuss these matters with you, of course. I can be reached
      directly at 617-421-5444.

    I
      acknowledged that Sonesta International Hotels Corporation is responsible for
      the adequacy and accuracy of the disclosures in its filings. Any comment from
      SEC staff or changes to the disclosures in responses to staff comments do not
      foreclose the Commission from taking any action with respect to the filings
      and
      we will not assert staff comments as a defense in any proceedings initiated
      by
      The Securities and Exchange Commission or any other person under the federal
      security laws of the United States.

    With
      kindest regards,

    Boy
      van
      Riel

    BVR/mac