SEC Comment Letter for INTERCONTINENTAL HOTELS GROUP (IHG) — Nov 30, 2012

INTERCONTINENTAL HOTELS GROUP PLC /NEW/
Date: Nov. 30, 2012 · CIK: 0000858446 · Accession: 0000000000-12-064704

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AI Filing Summary & Sentiment

Referenced dates: November 6, 2012

Date

November 29, 2012

Author

/s/ Cecilia Blye

Form

UPLOAD

Company

INTERCONTINENTAL HOTELS GROUP PLC /NEW/

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE November 29, 2012 Via E -mail Thomas Singer Chief Financial Officer InterContinental Hotels Group PLC Broadwater Park Denham , Buckinghamshire UB9 5HR United Kindgom

Re: InterContinental Hotels Group PLC Form 20 -F for the Fiscal Year Ended December 31, 2011 Filed March 29, 2012 File No. 1 -10409

Dear Mr. Singer:

We refer you to our comment letter dated November 6, 2012, regarding business contacts with Iran and Syria. We have completed our review of this subject matter. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respec t to the company or 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 federal securities laws of the United States. We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Cecilia Blye

Show Raw Text

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
       DIVISION OF
CORPORATION FINANCE
 November 29, 2012

Via E -mail
Thomas Singer
Chief Financial Officer
InterContinental Hotels Group PLC
Broadwater Park
Denham , Buckinghamshire UB9 5HR
United Kindgom

 Re: InterContinental Hotels Group PLC
  Form 20 -F for the Fiscal Year Ended December 31, 2011
  Filed March 29, 2012
  File No. 1 -10409

Dear Mr. Singer:

We refer you to our comment letter dated November 6, 2012,  regarding business contacts
with Iran and Syria.  We have completed our review of this subject matter.  We remind you that
our comments or changes to disclosure in response to our comments do not foreclose the
Commission from taking any action with respec t to the company or 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 federal securities laws of the United States.  We urge all persons who are
responsible for the a ccuracy and adequacy of the disclosure in the filing to be certain that the
filing includes the information the Securities Exchange Act of 1934 and all applicable rules
require.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global  Security Risk

cc:  Michael McTiernan
  Assistant Director
 Division of Corporation Finance

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