SecProbe.io

August 5, 2015

Via E -mail
Greg A. Dowell
Executive Vice President, Chief Financial Officer and Treasurer
Summit Hotel Properties, Inc.
12600 Hill Country Boulevard, Suite  R-100
Austin , TX  78738

Re: Summit Hotel Properties, Inc.
Form 10-K for the fiscal year ended December 31, 2014
Filed March 2, 2015
File No. 1 -9044

Dear Mr. Dowell:

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comment .  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advi se us as soon as possible when you will respond.  If you do not believe our
comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment, we may have additional comments.

Item 7. Management’s Discussion  and Analysis  of Financial Condition and Results of
Operations

Funds From Operations, page 35

1. We note that your reconciliation of FFO excludes the impact of preferred dividends .
Therefore it appears your FFO measure rep resents FFO attributable to common
shareholders and OP unitholders.  Please revise your presentation in future filings to
clearly label such measure.

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 respons ible for the accuracy
and adequacy of the disclosures they have made.

Greg A. Dowell
Summit Hotel Properties, Inc.
August 5, 2015
Page 2

  In responding to our comment , please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in t he 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 Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at
202.551.3486 with any questions.

Sincerely,

 /s/ Daniel L. Gordon

Daniel L. Gordon
Senior Assistant Chief Accountant