SecProbe.io

September 28, 2010

Mr. David L. White Chief Financial Officer Choice Hotels International, Inc. 10750 Columbia Pike Silver Spring, MD 20901
Re: Choice Hotels International, Inc.  Form 10-K for the year ended December 31, 2009
Filed March 1, 2010 File No. 001-13393
 Dear Mr. White:
 We have reviewed your filings and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within te n business days by amending your filings, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply 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 amendments to your f ilings and the information you provide in
response to these comments, we ma y have additional comments.

Proxy Statement on Schedule 14A, filed March 25, 2010

 Compensation Committee, page 15

 1. We note your response to comment 5 in our letter dated August 17, 2010 and Mr.
Pepper’s performance target of overseei ng the execution of 430 new franchise
agreements for 2009.  Please provide us with the actual number of franchise agreements executed that resulted in the 6% decr ease in Mr. Pepper’s 2009 incentive cash
compensation, and provide comparable disc losure in future filings.  See Items
402(b)(1)(v) and 402(b)(2)(vii) of Regulation S-K.     We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filings to be certain that the filings incl ude the information the Secu rities 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.

Mr. David L. White
Choice Hotels International, Inc. September 28, 2010 Page 2
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filings;

• 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 comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of  the United States.

Please contact Adam F. Turk at (202) 551-3657 or me at (202) 551-3785 with any
questions.
Sincerely,

Karen J. Garnett Assistant Director