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CORRESP

 Trip.com Group Limited

968 Jin Zhong Road

 Shanghai 200335

 People’s Republic of China

 February 8, 2023

VIA EDGAR

 Ms. Lilyanna Peyser

Ms. Cara Wirth

 Division of Corporation Finance

Office of Trade & Services

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
 Trip.com Group Limited (the “Company”)

Form 20-F for the Fiscal Year Ended December 31, 2021

Filed on April 27, 2022 (File
No. 001-33853)

Dear Ms. Peyser and Ms. Wirth,

 This
letter sets forth the Company’s responses to the comments contained in the letter dated January 26, 2023 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding
the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2021 filed with the Commission on April 27, 2022 (the “2021 Form
20-F”) and the Company’s response letters submitted on September 28, 2022 and December 1, 2022. The Staff’s comments are repeated below in bold and are followed by the
Company’s responses thereto. The proposed revised disclosure sets forth in the Company’s responses below reflects the Company’s cumulative revisions to the referenced disclosure in its future Form
20-F filings, with deletions shown as strike-through and additions shown as underlined. All capitalized terms used but not defined in this letter shall have the meaning ascribed to such terms in the 2021 Form 20-F.

 Response dated December 1, 2022

General

1.
 We note your proposed amended disclosure in response to comment 1. With respect to your definition of
“VIEs,” please refrain from stating that you conduct operations through the VIEs and revise to clearly state that you are the primary beneficiary of the VIEs for accounting purposes only.

 Division of Corporation Finance

Office of Trade & Services

 Securities and Exchange
Commission

 February 8, 2023

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 2

 In response to the Staff’s comment, the Company respectfully proposes to revise the
referenced disclosure as shown below in its future Form 20-F filings, subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed. The bold
text is added on top of the proposed disclosure in the Company’s prior response. Page reference is made to the 2021 Form 20-F to illustrate the approximate location of the disclosure.

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•

 “variable interest consolidated affiliated Chinese entities” or
“VIEs” refers to variable interest entities, which are companies incorporated in China that have entered into a series of contractual arrangements with their respective shareholders and our PRC subsidiaries. Under these contractual
arrangements, Trip.com Group Limited has a “controlling financing interest” in the VIEs as defined in FASB ASC 810 so that it is considered the primary beneficiary of the VIEs for accounting purposes only and thus consolidates each of
these entities under U.S. GAAP. The significant VIEs that Trip.com Group Limited consolidates under U.S. GAAP include We conduct some of our operations in China through the VIEs, primarily including(i) Shanghai
Ctrip Commerce Co., Ltd., or Ctrip Commerce (VIE), which holds a value-added telecommunications business license and mainly provides online advertising services, (ii) Shanghai Huacheng Southwest International Travel Agency Co., Ltd., or
Shanghai Huacheng (VIE), which holds a travel agency operation license and mainly provides domestic, inbound, and outbound tour services, and air-ticketing services, (iii) Chengdu Ctrip Travel Agency Co., Ltd., or Chengdu Ctrip (VIE), which
holds a domestic travel agency operation license and mainly provides air-ticketing services, and (iv) Beijing Qu Na Information Technology Co., Ltd., or Qunar Beijing (VIE), which holds the licenses,
approvals, and key assets such as mobile application and website that are essential to the business operations of Qunar. The contractual arrangements provide Trip.com Group Limited with a “controlling financial interest”
in the VIEs as defined in FASB ASC 810, making Trip.com Group Limited the primary beneficiary of the VIEs, and thereby consolidates each of these entities under
U.S. GAAP for accounting purpose;

2.
 We note your proposed amended disclosure in response to comment 2; please elaborate on the relevant laws and
regulations in Hong Kong and Macau, including a description on how they impact your business. At the beginning of Item 3, also disclose how regulatory actions related to data security or anti-monopoly concerns in Hong Kong/Macau have or may
impact the company’s ability to conduct its business, accept foreign investment or list on a U.S./foreign exchange.

 Division of Corporation Finance

Office of Trade & Services

 Securities and Exchange
Commission

 February 8, 2023

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 3

 The Company respectfully submits to the Staff that the Company has been in compliance with
relevant laws and regulations in Hong Kong and Macao. The Company further submits to the Staff that the main business activities of its subsidiaries in Hong Kong and Macao accounted for less than 1% of the Company’s total revenues in 2021, and
are expected to remain so in the foreseeable future. As such, the Company believes that the relevant laws and regulations in Hong Kong and Macao do not have a material impact on the Company’s business as of the date hereof. The Company
undertakes to closely monitor any update of relevant laws and regulations in Hong Kong and Macao in the future and make appropriate disclosures accordingly.

The Company also respectfully proposes to revise the referenced disclosure as shown below in its future Form
20-F filings, subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed. The bold text is added on top of the proposed disclosure in the
Company’s prior response. Page reference is made to the 2021 Form 20-F to illustrate the approximate location of the disclosure.

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 We face
various legal and operational risks and uncertainties relating to doing business in China. Our business operations are primarily conducted in China, and we are subject to complex and evolving PRC laws and regulations. For example, the PRC
government has recently issued statements and regulatory actions relating to areas such as the use of contractual arrangements in certain industries, we face risks associated with regulatory approvals on overseas offerings
and listings, by, and foreign investment in, China-based issuers, the use of our consolidated affiliated Chinese entities the VIEs, anti-monopoly regulatory
actions, and oversight on cybersecurity and data privacy. It remains uncertain how PRC government authorities will regulate overseas listings and offerings in general and whether we are required to complete filings or obtain any specific
regulatory approvals from the CSRC, the Cyberspace Administration of China, or the CAC, or any other PRC government authorities for our overseas offerings. In addition, if future regulatory developments mandate clearance of cybersecurity review or
other specific actions to be completed by China-based companies listed on foreign stock exchanges, such as us, we face uncertainties as to whether such clearance can be timely obtained, or at all. As of the date of this annual report,
regulatory actions relating to data security or anti-monopoly concerns in Hong Kong or Macao do not have a material impact on our ability to conduct business, accept foreign investment in the future, continue to list on a United States stock
exchange or maintain our listing status on the Hong Kong Stock Exchange. However, new regulatory actions relating to data security or anti-monopoly concerns in Hong Kong or Macao may be taken in the future, and there can be no assurance as to
whether such regulatory actions may have a material impact on our ability to conduct business, accept foreign investment, continue to list on a United States stock exchange or maintain our listing status on the Hong Kong Stock Exchange.
We face risks and uncertainties associated with not only these statements and regulatory actions, as well as but also the prospective uncertainties as to the inability of the Public Company
Accounting Oversight Board, or the PCAOB, to completely inspect registered public accounting firms headquartered in mainland China (including our independent auditor). lack of inspection on our auditors by the Public Company Accounting
Oversight Board, or the PCAOB, which These risks may impact our ability to conduct certain businesses, accept foreign investments, or list on a United States or other exchange outside China, . These risks and
could result in a material adverse change in our operations and the value of our ADSs, significantly limit or completely hinder our ability to continue to offer securities to investors, or cause the value of such securities to significantly
decline or become worthless. For a detailed description of risks relating to doing business in China, please refer to risks disclosed under “Item 3. Key Information—D. Risk Factors—Risks Relating to Doing Business in
China.”

 . . .

 Division of Corporation Finance

Office of Trade & Services

 Securities and Exchange
Commission

 February 8, 2023

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 4

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Our failure to comply with privacy and data protection laws and regulations in various jurisdictions could subject us to sanctions,
damages, and litigation, and could harm our reputation and business.

 . . .

European Union traditionally takes a broader view as to what is considered personal information and has imposed greater
obligations under their privacy and data protection laws. In particular, the European Union adopted a new General Data Protection Regulation in April 2016, which became effective in May 2018. The General Data Protection Regulation results in more
stringent requirements for data processors and controllers, including more fulsome disclosures about the processing of personal information, data retention limits, and deletion requirements, mandatory notification in the case of a data breach, and
elevated standards regarding valid consent in some specific cases of data processing. The General Data Protection Regulation also includes substantially higher penalties for failure to comply with the requirements. For example, in the event of
violations, a fine up to €20 million or up to 4% of the annual worldwide turnover, whichever is greater, may be imposed. In addition to General Data Protection Regulation, when other future laws and regulations relating to data privacy in
China or other jurisdictions come into effect, the more stringent requirements on privacy user notifications and data handling will require us to adapt our business and incur additional costs.

 Division of Corporation Finance

Office of Trade & Services

 Securities and Exchange
Commission

 February 8, 2023

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 5

 In addition, to the extent we have accessed data in Hong Kong and Macao,
we have been in compliance with relevant laws and regulations in both jurisdictions regarding data security, such as the Personal Data (Privacy) Ordinance and the Unsolicited Electronic Messages Ordinance, which impose
protocols and obligations regarding the handling of personal data in Hong Kong including, among other things, that (i) personal data must be collected for a lawful purpose, necessary, and not excessive,
(ii) personal data must be collected by means that are lawful and fair in the circumstances of the case, and (iii) the person from whom personal data is collected is informed of the
purpose of collecting the data. and as As of the date of this annual report, we believe that these laws and regulations in Hong Kong and Macao regarding
data security, such as the Personal Data (Privacy) Ordinance and the Unsolicited Electronic Messages Ordinance, which impose protocols and obligations regarding the handling of personal data in Hong Kong do not,
nor would any non-compliance therewith, if any, have any material adverse impact on our business. However, if certain laws and regulations in Hong Kong or Macao were to result in oversight over data security
that materially impacts our business in the applicable jurisdiction, we may be required to incur additional cost to ensure our compliance with such laws and regulations, and any violation could result in a material adverse impact on our business,
financial condition, and results of operations.

3.
 We note your proposed amended disclosure in response to comment 3 and we reissue it. Please revise your
Organizational Structure chart to disclose the 57% owners of Qunar Cayman Islands Limited.

 In response to the
Staff’s comment, the Company undertakes to further revise its corporate structure disclosed on pages 87 and 88 of the 2021 Form 20-F in “Item 4. Information of the Company—C. Organizational
Structure” substantially in the form of the diagram set forth in Appendix A attached hereto, which discloses the 57% owners of Qunar Cayman Islands Limited, and also replicate such diagram immediately after the heading of “Item 3.
Key Information—Our Holding Company Structure and Contractual Arrangements with the VIEs” in its future Form 20-F filings, subject to updates and adjustments to be made in connection with any
material development of the subject matter being disclosed. The bold text is added on top of the proposed disclosure in the Company’s prior response.

4.
 We note your proposed amended disclosure in response to comment 4, including your statement that “[a]s
a result of the contractual arrangements, we have effective control over and are (i) have the power to direct activities of the VIEs that most significantly affect their economic performance, and (ii) receive the economic benefits from the
VIEs that could be significant to them.” Please revise this sentence to reflect the conditions you have satisfied for consolidation of the VIE under U.S. GAAP and the fact that you are the primary beneficiary of the VIE for accounting purposes.

 Division of Corporation Finance

Office of Trade & Services

 Securities and Exchange
Commission

 February 8, 2023

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 6

 The Company respectfully clarifies to the Staff that, in its prior response to the
Staff’s comment, it has proposed to delete the statement that “we have effective control over the VIEs” by striking through such statement and has proposed to disclose the conditions it has satisfied for the consolidation of the VIEs
under U.S. GAAP. The Company respectfully submits to the Staff that, as defined in FASB ASC 810, a primary beneficiary is the reporting entity that holds a controlling financial interest in the VIE and thus is required to consolidate the VIE. The
two characteristics in connection with the determination of a “controlling financial interest” in a VIE are (i) the power to direct activities of the VIE that most significantly affect their economic performance, and (ii) the
right to receive the economic benefits from the VIE that could be significant to the VIE, as mentioned in the Company’s prior response to the Staff’s comment. In addition, the Company further clarifies that, in its prior response to the
Staff’s comment, it has proposed to disclose the fact that the Company is the primary beneficiary of the VIEs for accounting purposes.

In response to the Staff’s comment, the Company respectfully proposes to further revise the referenced disclosure as shown below in its
future Form 20-F filings, subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed. The bold text is added on top of the proposed
disclosure in the Company’s prior response. Page reference is made to the 2021 Form 20-F to illustrate the approximate location of the disclosure.

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 Our Holding Company
Structure and Contractual Arrangements with Our Consolidated Affiliated Chinese En