SecProbe.io

June 8, 2011
 Richard Solomons Chief Financial Officer InterContinental Hotels Group PLC Broadwater Park
Denham, Buckinghamshire UB9 5HR

Re: InterContinental Hotels Group PLC
Form 20-F for Fiscal Year Ended December 31, 2010 Filed April 11, 2011 File No. 001-10409

Dear Mr. Solomons:
 We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with informati on so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.

Richard Solomons
InterContinental Hotels Group PLC June 8, 2011 Page 2

Form 20-F

 Financial Statements

 Notes to Financial Statements

 Note 1 – Accounting policies

 General Information, page F-13

 1. It appears that you have reco rded a litigation provision of $22 million for the year ended
December 31, 2010.  Per review of Foot note 7 to your March 31, 2011 financial
statements included in Form 6-K file d on May 10, 2011, it appears you recorded an
additional $22 million for the three months ended March 31, 2011.  Please clarify for us
if you recorded a $22 million provision in both periods.  If provisions were recorded in
both periods, please tell us the facts and circum stances that led to the additional provision
during the first quarter 2011.    We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comment, please provide a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

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

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Jennifer Moni ck, Senior Staff Accountan t, at 202-551-3295 or me at
202-551-3629 if you have questions.
Sincerely,

Kevin Woody Branch Chief