SecProbe.io

October 17 , 2012

Via E-mail
Mr. Stuart J. Becker
Chief Financial  Officer
Summit Hotel Properties, Inc.
2701 South Minnesota Avenue, Suite 2
Sioux Falls, SD 57105

Re: Summit Hotel Properties, Inc.
  Form 10 -K for the Year Ended December 31, 2011
  Filed February 2 8, 201 2
  File No. 1-35074
 Summit Hotel OP, LP
  Form 10 -K for the Year Ended December 31, 2011
  Filed February 28, 2012
  File No. 0-54273

Dear M r. Becker :

We have reviewed your filing s and have the following comment s.  In our comment s, we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter via EDGAR within ten business days by providing the
requested information  or by advising us when you will provide the requested response.   If you do
not believe our comments apply to your facts and circumstances, please tell us why in your
response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Form 10 -K for the Year Ended December 31, 2011

Contractual Obligations, page 59

1. In future periodic filings, please revise your tabular presentation of contractual
obligations to include your interest commitme nts under your variable -rate interest -
bearing debt in this table, or provide textual discussion of this obligation below the table.
If you provide a textual discussion, the discussion should quantify the interest payments
using the same time frames stipula ted in the table. Regardless of whether you decide to
include interest payments in the table or in textual discussion below the table, you should
provide appropriate disclosure with respect to your assumptions of your estimated
variable rate interest payme nts.

Mr. Stuart J. Becker
Summit Hotel Properties, Inc.
October 17, 2012
Page 2

Consolidated Statements of Operations, page F -7

2. Please revise in future periodic filings to present the expense related to share -based
payment arrangements in the same line or lines as cash compensation paid to the same
employees.  Refer to SAB Topic 14F.

Note 16 – Equity -Based Compensation, page F -33

3. In future periodic filings, please include all disclosures required by ASC 718 -10-50,
including 1) for each year for which an income statement is provided, the weighted -
average grant -date fair val ue of equity options or other equity instruments granted during
the year, and 2) as of the latest balance sheet date presented, the total compensation cost
related to non -vested awards not yet recognized and the weighted -average period over
which it is exp ected to be recognized.

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 Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a writ ten statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking  any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Jonathan Wiggins , Staff  Accountant,  at (202) 551 -3694 or me at (202)
551-3486 if you have any questions.

Sincerely,

 /s/ Daniel L. Gordon

 Daniel L. Gordon
    Branch Chief