SecProbe.io

August 20, 2009

Via International Mail and Facsimile (011-44-1895-51-2471)

Richard Solomons Finance Director InterContinental Hotels Group PLC
Broadwater Park, Denham
Buckinghamshire UB9 5HR, U.K.
 Re: InterContinental Hotels Group PLC
  Form 20-F for the Fiscal Year Ended December 31, 2008
  Filed April 7, 2009   File No. 1-10409
Dear Mr. Solomons:

We have limited our review of your filing to disclosure relating to your contacts
with countries that have been  identified as state sponsors of  terrorism, and we have the
following comments.  Our review with respect to this issue does not preclude further
review by the Assistant Director group with respect to other issues.   At this juncture,
we are asking you to provide us with supplemental information, so that we may better understand your disclosure.  Please be as detail ed as necessary in your response.  After
reviewing this information, we may raise additional comments.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of
our review.  Feel free to call us at the tele phone numbers listed at th e end of th is letter.
 General

1. We note from your website that a new hotel in Syria, InterContinental Damascus,
is scheduled to open in 2012.  Syria is id entified by the U.S. Department of State
as a state sponsor of terrorism, and is  subject to U.S. economic sanctions and
export controls.  We note that your Fo rm 20-F does not include disclosure
regarding contacts with Syria.  Please desc ribe to us the nature and extent of your
past, current, and anticipated operations i n, or other contacts with, Syria, whether
through subsidiaries, joint ventures, or ot her direct or indirect arrangements.
Your response should describe any equipm ent or services you have provided to
Syria, directly or indirectly, and discu ss whether you have agents or employees in
Syria and any agreements, commercial arra ngements, or other contacts you have

Richard Solomons
InterContinental Hotels Group PLC
August 20, 2009 Page 2
had with the Syrian government or entit ies controlled by that governments.
2. You state on pages 18-19, 30-32, and elsewher e in the Form 20-F that you operate
in the Americas, the Middle East, and Africa, regional references generally
understood to encompass Cuba, Iran, and S udan.  We note that the 20-F does not
include disclosure regarding any contacts wi th those countries.  Please describe to
us the nature and extent of any past, cu rrent and anticipated contacts with Cuba,
Iran and Sudan, whether through subsidiaries, affiliates, or other direct or indirect arrangements.  With respect to any such  contacts, provide the same type of
information requested in the foregoing co mment regarding contacts with Syria.
3. Please discuss the materiality of any cont acts with Cuba, Iran, Syria, and Sudan,
and whether those contacts constitute a material investment risk for your security holders.  You should address materiality in quantitative term s, including the
approximate dollar amounts of revenues, a ssets, and liabilities associated with
Cuba, Iran, Syria, and Sudan for the last three fiscal years and any subsequent
period.  Also, address materiality in term s of qualitative factors that a reasonable
investor would deem important in maki ng an investment decision, including the
potential impact of corporate activit ies upon a company’s reputation and share
value.  As you may be aware, vari ous state and munici pal governments,
universities, and other inve stors have proposed or adopted divestment or similar
initiatives regarding investment in companies that do business with U.S.-
designated state sponsors of terrorism.  Y our materiality analysis should address
the potential impact of the investor sen timent evidenced by such actions directed
toward companies that have operations associated with Cuba, Iran, Syria, and
Sudan.

* * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a re sponse.  Please submit your response letter on EDGAR.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that th e filings include all in formation required under
the Exchange Act of 1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its management are in possession of all facts relating to the company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
 In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;

Richard Solomons
InterContinental Hotels Group PLC August 20, 2009 Page 3

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

Please understand that we may have addi tional comments after we review your
response to our comments.  Pl ease contact Pradip Bhaumik, Special Counsel, at (202)
551-3333 if you have any questions about the comments or our review.  You may also contact me at (202) 551-3470.          S i n c e r e l y ,             C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk  cc:  Karen Garnett   Assistant Director  Division of Corporation Finance