SEC Company Response from INTERCONTINENTAL HOTELS GROUP (IHG) — Sep 30, 2009

INTERCONTINENTAL HOTELS GROUP PLC /NEW/
Date: Sept. 30, 2009 · CIK: 0000858446 · Accession: 0000950103-09-002490

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AI Filing Summary & Sentiment

Referenced dates: September 29, 2009

Date

December 31, 2008

Author

Nicolette Henfrey

Form

CORRESP

Company

INTERCONTINENTAL HOTELS GROUP PLC /NEW/

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance InterContinental Hotels Group PLC Form 20-F for the Fiscal Year Ended December 31, 2008 Filed on April 7, 2009 File No. 1-10409

Dear Ms. Blye:

InterContinental Hotels Group PLC (the “Company”) is submitting this letter in connection with the letter dated September 29, 2009 submitted by Davis Polk & Wardwell LLP on the Company’s behalf in response to the written comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter, dated August 20, 2009 with respect to the above referenced filing on Form 20-F.

On behalf of the Company, I acknowledge that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in its filings; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking action with respect to the filings; and (iii) 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 are grateful for the Staff’s assistance in this matter and hope that the Staff is satisfied with our responses to the issues raised.

Please do not hesitate to call me, Nicolette Henfrey, with comments or questions.

Very truly yours,
/s/
Nicolette Henfrey

Show Raw Text

CORRESP
1
filename1.htm

    [IHG Letterhead]

      September
30, 2009

      VIA
EDGAR

      United
States Securities and Exchange Commission

      Division
of Corporation Finance

      100 F
Street, N.E.

      Washington,
D.C. 20549

      Attn:
Cecilia D. Blye

                Re:

                InterContinental
      Hotels Group PLC

                Form
      20-F for the Fiscal Year Ended December 31, 2008

                Filed
      on April 7, 2009

                File
      No. 1-10409

      Dear Ms.
Blye:

      InterContinental
Hotels Group PLC (the “Company”) is submitting this letter in connection with
the letter dated September 29, 2009 submitted by Davis Polk & Wardwell LLP
on the Company’s behalf in response to the written comments of the staff (the
“Staff”)  of the Securities and Exchange Commission (the “Commission”)
contained in your letter, dated August 20, 2009 with respect to the above
referenced filing on Form 20-F.

      On behalf
of the Company, I acknowledge that: (i) the Company is responsible for the
adequacy and accuracy of the disclosure in its filings; (ii) Staff comments or
changes to disclosure in response to Staff comments do not foreclose the
Commission from taking action with respect to the filings; and (iii) 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 are
grateful for the Staff’s assistance in this matter and hope that the Staff is
satisfied with our responses to the issues raised.

      Please do
not hesitate to call me, Nicolette Henfrey, with comments or
questions.

                Very truly yours,

                /s/
      Nicolette Henfrey

                Nicolette
Henfrey

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