SEC Comment Letter for Trip.com Group Ltd (TCOM, TRPCF) (CIK 0001269238) (TCOM) — Jan 23, 2013
Trip.com Group Ltd (TCOM, TRPCF) (CIK 0001269238)
Date: Jan. 23, 2013 · CIK: 0001269238 · Accession: 0000000000-13-003887
AI Filing Summary & Sentiment
Letter
January 23, 2013 Via E -mail Jenny Wu Chief Financial Officer Ctrip.com International, Ltd. 99 Fu Quan Road Shanghai 200335 People’s Republic of China
Re: Ctrip.com International, Ltd. Form 20-F for the Fiscal Year Ended December 31, 201 1 Filed on March 30, 2012 Form 6 -K filed September 12, 2012 Form 6 -K filed September 25, 2012 File No. 001 -33853
Dear Ms. Wu:
We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initia ted by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Se curities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Kathleen Collins
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January 23, 2013 Via E -mail Jenny Wu Chief Financial Officer Ctrip.com International, Ltd. 99 Fu Quan Road Shanghai 200335 People’s Republic of China Re: Ctrip.com International, Ltd. Form 20-F for the Fiscal Year Ended December 31, 201 1 Filed on March 30, 2012 Form 6 -K filed September 12, 2012 Form 6 -K filed September 25, 2012 File No. 001 -33853 Dear Ms. Wu: We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initia ted by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Se curities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief cc: Via E -mail Jane Sun – Ctrip.com International Julie Gao - Skadden, Arps, Slate, Meagher & Flom