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
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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