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SEC Comment Letter for Trip.com Group Ltd (TCOM, TRPCF) (CIK 0001269238) (TCOM) — Sep 19, 2013

Trip.com Group Ltd (TCOM, TRPCF) (CIK 0001269238)
Date: Sept. 19, 2013 · CIK: 0001269238 · Accession: 0000000000-13-051522

AI Filing Summary & Sentiment

Date
December 31, 2012
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
Trip.com Group Ltd (TCOM, TRPCF) (CIK 0001269238)

Letter

September 1 8, 2013 Via E -mail Jenny Wenjie 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 Fiscal Year Ended December 31, 2012 Filed March 29, 2013 File No. 1 -33853

Dear Ms. Wu:

We refer you to our comment letter dated September 10 , 2013, regarding business contacts with Cuba, Sudan and Syria . We have completed our review of this subject matter. 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 asse rt staff comments as a defense in any proceeding initiated 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 includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
September 1 8, 2013

Via E -mail
Jenny Wenjie 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 Fiscal Year Ended December 31, 2012
  Filed March 29, 2013
  File No. 1 -33853

Dear Ms. Wu:

We refer you to our comment letter dated September 10 , 2013, regarding business
contacts with Cuba, Sudan and Syria .  We have completed our review of this subject matter.  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 asse rt staff comments as a defense in any proceeding initiated 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 includes the information the Securities Exchange Act of 1934 and all
applicable rules require.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Barbara Jacobs
  Assistant Director
 Division of Corporation Finance

 Z. Julie Gao, Esq.
Skadden, Arps, Slate, Meagher & Flom