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CORRESP
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 CORRESP

 Ms. Jennifer Monick
 Mr. Eric McPhee Division of Corporation Finance
 Office of Real Estate & Construction Securities and
Exchange Commission 100 F Street, N.E. Washington, D.C.
20549 Re: Choice Hotels International, Inc. Form
 10-K for the year ended December 31, 2025 Form 8-K filed
February 19, 2026 File No. 001-13393
 April 16, 2026 Dear Ms. Monick and Mr. McPhee:
 Choice Hotels International, Inc. (the “Company,” “Choice,” “we,” or “our”) is submitting this letter in
response to the comment letter dated April 6, 2026 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), regarding the Company’s Annual Report on Form 10-K for the year ended December 31, 2025 (the “Form 10-K”) and Current Report on Form 8-K filed on February 19,
2026 (the “Form 8-K”). For ease of reference, we have retyped the text of the Staff’s comments in italics below.
 Form 10-K for the year ended December 31, 2025
 Management’s Discussion and Analysis of Financial Condition and Results of Operations
 Operations Review, page 40

 1.
 Please tell us what consideration you have given to including a discussion, within your results of
operations, of any known trends or uncertainties that have had or are reasonably likely to have a material effect on your revenues, expenses or net income. Your response should address, but not necessarily be limited to, what consideration you gave
to discussing the impact of reduced government and international travel, which you discussed during your earnings calls for periods ending in 2025. Refer to Items 303(a) and (b)(2)(ii) of Regulation S-K and
trend information within Releases No.33-6835 and 33-8350.
 The Company respectfully acknowledges the Staff’s comment. We considered the requirements of Items 303(a) and (b)(2)(ii) of Regulation
S-K and the trend information within Releases No. 33-6835 and 33-8350, in determining whether to disclose within Management’s Discussion and Analysis of Financial Condition and Results of Operations section of the Form 10-K any known trends or uncertainties that have had or are reasonably likely to have a material effect on the Company’s revenues, expenses, or net income.
 In performing this evaluation, we considered the changes in government and international travel during the periods ending in 2025. Although we
mentioned “our fourth-quarter results were also affected by the government shutdown and continued softness in international inbound travel” during our earnings calls for the periods ending in 2025, the impact was immaterial to the
Company’s consolidated revenues, expenses, and net income for the year ended 2025 as the total of government and international travel represents an immaterial portion (less than 5%) of the

Company’s overall demand for travel across our US hotel portfolio. It should be noted that the aggregate impact of that reduced demand on our financial statements is further reduced based
on the nature of our position as franchisor, in which we generate revenues through a percentage fee of our third-party hotel owner’s revenues. Given that our disclosures are for the full-year period, and the impact was not material, we
concluded that inclusion within Management’s Discussion and Analysis of Financial Condition and Results of Operations section of the Form 10-K was not warranted.
 We will continue to evaluate these factors in future periods and will provide additional disclosure if we determine that a known trend or
uncertainty is reasonably likely to have a material effect on the Company’s revenues, expenses or net income. Furthermore, we will continue to evaluate the consistency of our disclosures over known trends within Management’s Discussion
and Analysis and other publicly available information, including statements made in earnings releases or earnings calls. Notes to Consolidated
Financial Statements 17. Acquisitions, page 91

 2.
 We note your disclosure that the fair value of the reacquired territory rights and the franchise agreements
were valued using a valuation methodology that utilizes Level 3 inputs. Please tell us how you determined it was not necessary to provide quantitative information about the significant unobservable inputs used in such fair value measurement.
Please refer to ASC 820-10-50-2(bbb).
 The Company respectfully acknowledges the Staff’s comment and the disclosure requirements in ASC 820-10-50-2(bbb) related to providing quantitative information about the significant unobservable inputs used in fair value measurements.
 The fair values of the reacquired territory rights and the franchise agreements were determined using valuation techniques that incorporate
unobservable inputs. While these inputs are unobservable, we determined that providing quantitative information about individual unobservable inputs would not be meaningful to investors for the following reasons:

 •

 The valuation models used multiple interrelated unobservable inputs, including future cash flows, royalty rates,
and discount rates, that are developed and evaluated collectively, and changes to one input would not be meaningful without corresponding changes to the other inputs. Further, there was little sensitivity in the unobservable inputs as reasonable
changes to the unobservable inputs do not materially impact the valuation of the reacquired territory rights and the franchise agreements. We concluded that no individual unobservable input was independently significant, as changes to any individual
unobservable input would not be meaningful in isolation and would not materially impact the valuation.

 •

 The Company believes its existing qualitative disclosures appropriately describe the nature of the unobservable
inputs, valuation methodologies, and judgments applied, and therefore satisfy the objectives of the disclosure requirements in ASC 820.
 The Company will continue to evaluate the significance of any unobservable inputs in future transactions and to the extent that such
unobservable inputs are significant and the quantitative disclosures are meaningful to investors, then we will disclose the quantitative information about the significant unobservable inputs used in the respective fair value measurements.

 Form 8-K filed February 19, 2026
 Exhibits

 3.
 We refer you to Exhibit 99.1. We note that your calculation of EBITDA contains adjustments for items other
than interest, taxes, depreciation and amortization. Please revise future earnings releases to ensure that measures calculated differently from EBITDA are not characterized as EBITDA, or advise. Reference is made to Question 103.01 of the
Corporation Finance Interpretations for Non-GAAP Financial Measures. The
Company respectfully acknowledges the Staff’s comment. We will remove the calculation of EBITDA in future filings because Adjusted EBITDA is the primary metric utilized to communicate our financial results to investors. Noted below is a
revised presentation of the Adjusted EBITDA reconciliations for the three months and twelve months ended December 31, 2025 and 2024 that reflects this change, and a presentation of the 2026 Outlook for the full year ended December 31, 2026
that reflects this change. Exhibit 6
 CHOICE HOTELS INTERNATIONAL, INC.
 NON-GAAP FINANCIAL INFORMATION
 (UNAUDITED) ADJUSTED EARNINGS BEFORE
INTEREST, TAXES, DEPRECIATION AND AMORTIZATION (“ADJUSTED EBITDA”)

 (dollar amounts in thousands)

 Three Months Ended

 Year Ended

 December 31,

 December 31,

 2025

 2024

 2025

 2024

 Net income

 $
 63,682

 $
 75,804

 $
 369,946

 $
 299,665

 Income tax expense

 13,920

 25,904

 86,945

 95,980

 Interest expense

 23,680

 21,067

 91,148

 87,131

 lnterest income

 (1,787
 )

 (2,089
 )

 (6,237
 )

 (8,646
 )

 Depreciation and amortization

 16,783

 13,408

 59,715

 51,953

 Amortization of cloud computing arrangements

 324

 — 

 513

 — 

 Gain from an acquisition of a joint venture

 — 

 — 

 (100,025
 )

 — 

 Gain on sale of assets

 — 

 — 

 (713
 )

 — 

 Loss on extinguishment of debt

 — 

 — 

 — 

 331

 Other (gains) losses, net

 (1,330
 )

 1,774

 (6,989
 )

 1,641

 Equity in net loss (gain) of affiliates

 3,289

 (3,241
 )

 14,324

 (12,329
 )

 Share-based compensation

 3,083

 5,634

 21,606

 21,118

 Mark to market adjustments on non-qualified retirement
plan investments

 1,153

 224

 7,060

 7,409

 Franchise agreement acquisition cost amortization and charges

 4,478

 3,361

 20,062

 14,953

 Revenue for reimbursable costs from franchised and managed properties

 (155,997
 )

 (161,116
 )

 (616,204
 )

 (638,192
 )

 Reimbursable expenses from franchised and managed properties

 158,899

 154,487

 663,336

 656,344

 Global ERP system implementation and related costs

 2,264

 791

 5,917

 1,377

 Business combination, diligence and transition costs (recoveries)

 2,761

 (490
 )

 4,701

 17,233

 Non-recurring operational restructuring charges and
executive severance

 5,720

 4,895

 10,519

 5,683

 Expenses associated with legal claims

 — 

 — 

 — 

 2,430

 Adjusted EBITDA

 $
 140,922

 $
 140,413

 $
 625,624

 $
 604,081

 Exhibit 7
 CHOICE HOTELS INTERNATIONAL, INC.
 OUTLOOK (UNAUDITED)
 Guidance represents the company’s range of estimated outcomes for the full year ended December 31, 2026
 ADJUSTED EBITDA

 (in thousands)

 Full Year Lower Range

 Full Year Upper Range

 Net income

 $
 265,000

 $
 275,000

 Income tax expense

 88,200

 91,800

 Interest expense

 87,600

 89,000

 Interest income

 (6,500
 )

 (6,500
 )

 Depreciation and amortization

 64,500

 64,500

 Amortization of cloud computing arrangements

 1,200

 1,200

 Other losses, net

 100

 100

 Equity in net loss of affiliates

 11,900

 11,900

 Share-based compensation

 20,700

 20,700

 Franchise agreement acquisition cost amortization and charges

 26,100

 26,100

 Revenue for reimbursable costs from franchised and managed properties

 (605,300
 )

 (605,300
 )

 Reimbursable expenses from franchised and managed properties

 675,300

 675,300

 Global ERP system implementation and related costs

 1,700

 1,700

 Business combination, diligence and transition costs

 1,500

 1,500

 Adjusted EBITDA

 $
 632,000

 $
 647,000

 Please do not hesitate to call me at (301) 592-6659 with any questions or further
comments you may have or if you wish to discuss the above responses.

 Regards,

 CHOICE HOTELS INTERNATIONAL, INC.

 By:

 /s/ Scott E. Oaksmith

 Name:

 Scott E. Oaksmith

 Title:

 Chief Financial Officer