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SEC Company Response from GreenTree Hospitality Group (GHG) — Mar 26, 2018

GreenTree Hospitality Group Ltd.
Date: March 26, 2018 · CIK: 0001724755 · Accession: 0001193125-18-094992

AI Filing Summary & Sentiment

File numbers found in text: 333-223261

Date
March 26, 2018
Author
/s/ Chris K.H. Lin
Form
CORRESP
Company
GreenTree Hospitality Group Ltd.

Letter

Simpson Thacher & Bartlett

ICBC TOWER, 35TH FLOOR

3 GARDEN ROAD

HONG KONG

TELEPHONE: +852-2514-7600

FACSIMILE: +852-2869-7694

Direct Dial Number

(852) 2514-7650

E-mail Address

clin@stblaw.com

March 26, 2018

VIA EDGAR

Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street N.E.

Mail Stop 3233

Washington, D.C. 20549

Attention: Ms. Kim McManus, Esq., Senior Attorney

Mr. Joshua Lobert, Esq., Staff Attorney

Mr. Isaac Esquivel, Staff Accountant

Ms. Kristi Marrone, Staff Accountant

Re: GreenTree Hospitality Group Ltd.

Amendment No. 1 to Registration Statement on Form F-1

Filed March 14, 2018

File No. 333-223261

Ladies and Gentlemen:

On behalf of our client, GreenTree Hospitality Group Ltd., an exempted company incorporated under the laws of the Cayman Islands with limited liability (the “Company”), we enclose herewith for filing via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, Amendment No. 3 (“Amendment No. 3”) to the Company’s above-referenced registration statement on Form F-1 (the “Registration Statement”).

We enclose herewith ten (10) courtesy copies of Amendment No. 3, which has been marked to show changes to the Registration Statement filed with the Commission on March 14, 2018 (the “March 14 Filing”).

The Company has revised the March 14 Filing to reduce the number of Class A ordinary shares, represented by American depositary receipts, to be offered in its initial public offering, as well as make related updates to the disclosure.

The Company expects to price its initial public offering today, March 26, 2018 and, along with the underwriters, has submitted a request to the staff of the Commission pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933 to request that the effectiveness of the above-referenced registration statement (the “F-1 Registration Statement”) be accelerated to, and that the F-1 Registration Statement become effective at, at, 4:00 P.M., Eastern Daylight Time today, March 26, 2018, or as soon as practicable thereafter.

We greatly appreciate the Staff’s cooperation with the Company to achieve this offering timetable.

* * * * *

If you have any question regarding the Registration Statement, please do not hesitate to contact me at +852-2514-7650 (work), +852-9198-4235 (mobile) or clin@stblaw.com (email) or Howie Farn at +852-2514-7668 (work), +852-6710-2672 (mobile) or hfarn@stblaw.com (email).

Very truly yours,
/s/ Chris K.H. Lin

Show Raw Text
CORRESP
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filename1.htm

CORRESP

 Simpson Thacher & Bartlett

 ICBC TOWER, 35TH FLOOR

3 GARDEN ROAD

HONG KONG

TELEPHONE: +852-2514-7600

FACSIMILE: +852-2869-7694

 Direct Dial Number

 (852) 2514-7650

 E-mail Address

clin@stblaw.com

 March 26, 2018

VIA EDGAR

 Division of Corporation Finance

U.S. Securities & Exchange Commission

 100 F Street N.E.

 Mail Stop 3233

 Washington, D.C. 20549

Attention:
Ms. Kim McManus, Esq., Senior Attorney

Mr. Joshua Lobert, Esq., Staff Attorney

Mr. Isaac Esquivel, Staff Accountant

Ms. Kristi Marrone, Staff Accountant

        Re:
GreenTree Hospitality Group Ltd.

      Amendment No. 1 to Registration Statement on Form F-1

Filed March 14, 2018

File No. 333-223261

 Ladies and Gentlemen:

On behalf of our client, GreenTree Hospitality Group Ltd., an exempted company incorporated under the laws of the Cayman Islands with limited
liability (the “Company”), we enclose herewith for filing via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, Amendment No. 3 (“Amendment
No. 3”) to the Company’s above-referenced registration statement on Form F-1 (the “Registration Statement”).

We enclose herewith ten (10) courtesy copies of Amendment No. 3, which has been marked to show changes to the Registration Statement
filed with the Commission on March 14, 2018 (the “March 14 Filing”).

 The Company has revised the March 14 Filing to reduce the number of Class A ordinary
shares, represented by American depositary receipts, to be offered in its initial public offering, as well as make related updates to the disclosure.

The Company expects to price its initial public offering today, March 26, 2018 and, along with the underwriters, has submitted a request
to the staff of the Commission pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933 to request that the effectiveness of the above-referenced registration statement (the
“F-1 Registration Statement”) be accelerated to, and that the F-1 Registration Statement become effective at, at, 4:00 P.M., Eastern Daylight Time today,
March 26, 2018, or as soon as practicable thereafter.

 We greatly appreciate the Staff’s cooperation with the Company to achieve
this offering timetable.

*      *      *      *
  *

 2

 If you have any question regarding the Registration Statement, please do not hesitate to contact
me at +852-2514-7650 (work), +852-9198-4235 (mobile) or clin@stblaw.com (email) or Howie Farn at +852-2514-7668 (work), +852-6710-2672 (mobile) or hfarn@stblaw.com (email).

Very truly yours,

/s/ Chris K.H. Lin

Chris K.H. Lin

 Enclosures

cc:
Alex S. Xu, Chairman and Chief Executive Officer

 Xin Yue Jasmine Geffner, Chief Financial
Officer

 GreenTree Hospitality Group Ltd.

Daniel Fertig

 Howie Farn

Simpson Thacher & Bartlett

Allen C. Wang

 Latham &
Watkins LLP

 Alfred Yin

Ernst & Young Hua Ming LLP

Shirley Wong

 Ernst &
Young LLP

 3