SecProbe.io

December 30, 2011
 Mr. David L. White Chief Financial Officer Choice Hotels International, Inc. 10750 Columbia Pike Silver Spring, Maryland 20901

Re: Choice Hotels International, Inc.
  Form 10-K for the year  ended December 31, 2010
Filed on March 1, 2011 File No. 001-13393

Dear Mr. David L. White:
We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other porti ons of your documents.   In 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 providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us why in your response.

 After reviewing the information you provide  in response to these comments, we may
have additional comments.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2010

 Financial Statements and Notes

 Consolidated Statements Of Income, page 72

1. We note that you have included dividends d eclared per common share on the face of your
Consolidated Statements of Operations versus  in the notes to your financial statements.
Tell us how your disclosure complies with th e guidance in paragraph 260-10-45-5 of the
FASB Accounting Standards Codification.

Mr. David L. White Choice Hotels International, Inc. December 30, 2011 Page 2

 Note 27 – Commitments and Contingencies, pages 115 – 116

2. Reference is made to your disclosures on pa ge 35 where you indicate that ongoing legal
proceedings will not have a material advers e effect individually or collectively.
However, within your footnote disclosures,  you only make reference on an individual
basis.   Please clarify whether ongoing lega l proceeding will have a material adverse
effect on a collective basis.   If it will not, please revise footnote disclosures in future
filings to indicate that fact.
 FORM 10-Q FOR THE PERIODS ENDED MARCH 31, JUNE 30, SEPTEMBER 30, 2011

Note 1 – Company Information a nd Significant Accounting Policies

3. Please clarify whether all adjustments are norma l recurring adjustments.   If so, please
revise future filings to provide a statement to  that effect.   If not , please describe in
appropriate detail the nature and amount of any adjustments other than normal recurring
adjustments.   Reference is made to  Rule 10-01(b)(8) of Regulation S-X.

In responding to our comments, please provi de a written statement from the company
acknowledging that:

 the company is responsible for the adequacy an d 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.

You may contact Wilson K. Lee at (202)  551 – 3468 or me at (202) 551 – 3438  if you
have any questions.
Sincerely,
  /s/ Robert F. Telewicz Jr.   Robert F. Telewicz Jr.  Staff Accountant