SecProbe.io

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      November 30, 2005

Via U.S. Mail and Facsimile

Isadore Sharp
Chief Executive Officer
1165 Leslie Street
Toronto, Ontario
Canada, M3C 2K8

David A. Katz
Wachtell, Lipton, Rosen & Katz
51 West 52nd Street
New York, NY 10019-6150

RE:		Four Seasons Hotels Inc.
      40-F for the fiscal year ended December 31, 2004
      Response Letter dated October 18, 2005
		File No. 001-14572

Dear Mr. Sharp:

      We have reviewed the above filing and response letter and
have
the following comment.  We have limited our review of your Form
40-F
to disclosures relating to your contacts with countries that have
been identified as state sponsors of terrorism, and will make no
further review of the Form 40-F.  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 detailed as
necessary in your response. After reviewing this information, we
may
or may not raise additional comments.

General -

We note that in your letter of October 18, 2005, you state that
"in
the Company`s view, neither its involvement with the Damascus
Hotel
nor its contacts in Syria constitute a material investment risk
for
security holders, including with respect to qualitative factors
such
as reputation and share value."  Your conclusion with respect to
qualitative factors such as reputation and share value appears to
be
based solely on your view that your dealings with Syria have been
in
compliance with U.S. regulations involving Syrian entities and
individuals.  Please provide us with your views as to materiality
of
your involvement with the Damascus Hotel and other contacts with
Syria, and whether they constitute a material investment risk for
your security holders notwithstanding that they may have been
conducted in compliance with relevant U.S. regulations, when
considered in light of the potential impact upon your reputation
and
share value of your status as a party to transactions and
agreements
with and/or in a country identified as a state sponsor of
terrorism
and subject to U.S. sanctions imposed, in part, as a result of its
actions in support of terrorism and its pursuit of weapons of mass
destruction and missile programs.  Provide us with both your
conclusions and underlying analysis.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information 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.

      Please be advised that the Division of Enforcement has
access
to all information you provide to the staff of the Division of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Karen Garnett
		Assistant Director
		Division of Corporation Finance

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