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    Davis
                                            Polk & Wardwell

                                            Hong Kong Solicitors

    The Hong Kong Club Building

    3A Chater Road

    Hong Kong

    davispolk.com

    Resident Hong Kong
    Partners

    James C. Lin *

    Gerhard Radtke *

    Martin Rogers **
    Miranda
                                       So *

    James Wadham **

    Xuelin Wang *

    Hong Kong
    Solicitors

    * Also Admitted in New York

    ** Also Admitted in England and Wales

June 26, 2024

Division of Corporation Finance

Office of Real Estate & Construction

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:
    Atour Lifestyle Holdings Limited

    Form 20-F for the Year Ended December 31, 2023

    Filed April 26, 2024

    File No. 001-40540

    Attn:
    Division of Corporation Finance

    Office of Real Estate & Construction

VIA EDGAR

Dear Babette Cooper, Mark Rakip, Ronald E. Alper
and Brigitte Lippmann:

This letter sets forth the responses of Atour
Lifestyle Holdings Limited (the “Company”) to the comments the Company received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) in a letter dated June 18, 2024. For the Staff’s
convenience, we have included herein the Comments in bold, and the Company’s responses are set forth immediately below the Comments.

General Note
to the Staff:

The Company respectfully submits in this letter
its proposed amendments to the disclosures contained in the Company’s annual report on Form 20-F for the fiscal year ended
December 31, 2023 filed with the Commission on April 26, 2024 (the “2023 Annual Report”) (with deletions
shown as strike-through and additions underlined).

Subject to the Staff’s
further review and comment, the Company undertakes to include the proposed disclosures substantially as set forth below in its
annual report on Form 20-F for the fiscal year ending December 31, 2024 (the “2024 Annual Report”), with
appropriate revisions and updates to reflect the Company’s circumstances at the time when it files the 2024 Annual Report. All capitalized
terms used but not defined in this letter shall have the meaning ascribed to such terms in the 2023 Form 20-F.

    1

Form 20-F for the Year Ended December 31, 2023

Item 3. Key Information, page 1

1. At the outset of Item 3, provide prominent disclosure about the
legal and operational risks associated with being based in or having the majority of the company’s operations in China. Your disclosure
should make clear whether these risks could result in a material change in your operations and/or the value of your securities or could
significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless. Your disclosure should address how recent statements and regulatory actions by China’s
government, such as those related to data security or anti-monopoly concerns, have or may impact the company’s ability to conduct
its business, accept foreign investments, or list on a U.S. or other foreign exchange.

In response to the Staff’s comments, the
Company respectfully advises the Staff that it proposes to revise the referenced disclosures at the outset of Item 3 as follows on the
page 1 of its 2024 Annual Report (with additions underlined).

“ITEM 3. KEY INFORMATION

Holding Company Structure

…

In
addition, we face various legal and operational risks and uncertainties related to being based in and having a significant
portion of our operations in China. The PRC regulatory authorities have significant oversight and discretion over the conduct of our business
and may influence our operations as they deem appropriate to further economic, regulatory, political, and societal goals. The PRC regulatory
authorities have issued new policies covering cybersecurity, data privacy, antitrust, foreign investments, and overseas securities listings,
requiring or potentially requiring us to undergo additional regulatory approvals and filings for our business operations, acceptance of
foreign investments, and future overseas financing activities. For example, any future offerings and listings of our securities in overseas
markets will need to comply with the filing requirements under the CSRC Filing Rules (as defined below). Furthermore, we cannot rule out
the possibility that the PRC regulatory authorities will in the future release regulations or policies regarding our industry that could
adversely affect our business, financial condition and results of operations. These risks could result in a material change in our operations
and the value of the ADSs, significantly limit or completely hinder our ability to offer or continue to offer securities to investors
or cause the value of such securities to significantly decline or be worthless. For more details, see “Item 3. Key Information—Recent
Regulatory Developments” on pages 2 and 3 of this annual report, “Item 3. Key Information—Permissions Required
from the PRC Authorities for Our Operations and Overseas Securities Offerings” on page 4 of this annual report, and “Item
3. Key Information—3.D. Risk Factors—Risks Related to Doing Business in China” from page 29 through page 39
of this annual report.”

2. Under Implication of the Holding Foreign Companies Accountable
Act, please disclose the location of your auditor’s headquarters.

In response to the Staff’s comments, the
Company respectfully advises the Staff that it proposes to revise the referenced disclosures under Implication of the Holding Foreign
Companies Accountable Act as follows on page 3 of its 2024 Annual Report (with additions underlined).

“Implication of the Holding Foreign
Companies Accountable Act

Trading
in our securities on U.S. markets, including Nasdaq, may be prohibited under the Holding Foreign Companies Act, as amended by the Consolidated
Appropriations Act, 2023 (the “HFCAA”), if the PCAOB determines that it is unable to inspect or investigate completely our
auditor for two consecutive years. On December 16, 2021, the PCAOB issued the HFCAA Determination Report to notify the SEC of its
determinations that the PCAOB was unable to inspect or investigate completely registered public accounting firms headquartered in mainland
China and Hong Kong, including our auditor which is headquartered in mainland China. The inability of the PCAOB to conduct inspections
in the past also deprived our investors of the benefits of such inspections. On December 15, 2022, the PCAOB announced that it was
able to conduct inspections and investigations completely of PCAOB-registered public accounting firms headquartered in mainland China
and Hong Kong in 2022. The PCAOB vacated its previous 2021 determinations accordingly.”

    2

Item 3.D. Risk Factors, page 4

3. In your summary of risk factors, disclose the risks that your
corporate structure and having the majority of the company’s operations in China poses to investors. In particular describe the
significant regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks elsewhere.
For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement
of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese government
may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment
in China-based issuers, which could result in a material change in your operations and/or the value of your securities. Acknowledge any
risks that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or
foreign investment in China-based issuers could significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless.

In response to the Staff’s comments, the Company respectfully
advises the Staff that it proposes to revise the referenced disclosures in the summary of risk factors as follows on page 5 of its
2024 Annual Report (with additions underlined).

“Risks Related to Doing Business
in China

 · We conduct all of our operations in China and all of our revenue is derived
from our operations in China. Accordingly, our results of operations and prospects are subject to economic, political and legal developments
in China.  Changes in China’s economic, political or social conditions or government policies could have a material adverse
effect on our business and operations. For a detailed discussion of the underlying risks, see “Item 3. Key Information—3.D.
Risk Factors—Risks Related to Doing Business in China—Changes in China’s economic, political or social conditions
or government policies could have a material adverse effect on our business, financial condition and results of operations” on
pages 29 and 30 of this annual report.

 · Since legal system in China continues to evolve rapidly, the interpretation
and enforcement of many laws, regulations and rules involve uncertainties, and these laws, regulations and rules can change
quickly with little advance notice. In addition, the Chinese government has significant oversight and discretion over the conduct of our
business and may intervene or influence our operations at any time, which could result in a material change in our operations and/or the
value of our securities. For a detailed discussion of the underlying risks, see “Item 3. Key Information—3.D. Risk Factors—Risks
Related to Doing Business in China—Uncertainties with respect to the PRC legal system, including uncertainties regarding
the enforcement of laws, and sudden or unexpected changes in laws and regulations in China could adversely affect us and limit
the legal protections available to you and us” on page 30 of this annual report.

 · The Chinese government may exert more oversight and control over offerings
that are conducted overseas and/or foreign investment in China-based issuers, which could significantly limit or completely hinder our
ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.
For a detailed discussion of the underlying risks, see “Item 3. Key Information—3.D. Risk Factors—Risks Related to The
ADSs—The approval or filing of the China Securities Regulatory Commission or other PRC regulatory agencies may be required to maintain
our listing status or conduct future offshore securities offerings” on page 43 of this annual report.

 · Our online platform business is subject to various internet-related laws
and regulations. These internet-related laws and regulations are relatively new and evolving, and their enactment timetable, interpretation
and implementation involve certain uncertainties. For a detailed discussion of the underlying risks, see “Item 3. Key Information—3.D.
Risk Factors—Risks Related to Doing Business in China—Uncertainties exist with respect to the enactment timetable, interpretation
and implementation of the laws and regulations with respect to our online platform business operation” on page 31 of this
annual report.

 · Our auditor is headquartered in mainland China, a jurisdiction where the
PCAOB has historically been unable to conduct inspections and investigations of auditors completely. Trading in our securities may be
prohibited under the HFCAA if the PCAOB determines that it is unable to inspect or investigate completely our auditor, and as a result,
U.S. national securities exchanges, such as Nasdaq, may determine to delist the ADSs. For a detailed discussion of the underlying risks,
see “Item 3. Key Information—3.D. Risk Factors—Risks Related to Doing Business in China—Trading in our securities
may be prohibited under the HFCAA if the PCAOB determines that it is unable to inspect or investigate completely our auditor, and as a
result, U.S. national securities exchanges, such as Nasdaq, may determine to delist the ADSs” on pages 31 and 32 of this
annual report.

    3

 · It may be challenging to effect service of legal process, enforce foreign
judgments or bring actions in China against us or our management based on foreign laws. For a detailed discussion of the underlying risks,
see “Item 3. Key Information—3.D. Risk Factors—Risks Related to Doing Business in China—You may experience
difficulties in effecting service of legal process, enforcing foreign judgments or bringing actions in China against us or our management
based on foreign laws” on page 33 of this annual report.

 · We are a Cayman Islands holding company and we rely principally on dividends
and other distributions on equity from our PRC subsidiaries for our cash and financing requirements. Any limitation on the ability of
our PRC subsidiaries to make payments to us could have a material and adverse effect on our ability to conduct our business. For a detailed
discussion of the underlying risks, see “Item 3. Key Information—3.D. Risk Factors—Risks Related to Doing Business in
China—We may rely on dividends and other distributions on equity paid by our PRC subsidiaries to fund any cash and financing requirements
we may have, and any limitation on the ability of our PRC subsidiaries to make payments to us could have a material and adverse effect
on our ability to conduct our business” on pages 33 and 34 of this annual report.

Risks Related to Doing Business in China, page 29

4. We note the changes made to your disclosure in this section,
including the risk factors on pages 29, 30, 36, and 39, compared to the language used in your initial public offering registration
statement. However, it is unclear that there have been changes in the regulatory environment in the PRC since your initial public offering
registration statement was filed that would warrant the revised disclosure mitigating the risks related to doing business in China. Please
tell us and revise your disclosure in future filings to revert to the language used in your initial public offering registration statement
on Form F-1 dated November 7, 2022. Additionally, please tell us and revise your disclosure in future filings to explain the
basis for your statement on page 30 that: “The overall effect of legislation over the past three decades has significantly
enhanced the protections afforded to various forms of foreign investments in China.”

The Company respectfully advises the Staff that the changes made to
the referenced disclosure in this section, compared to the language used in the F-1 registration statement for its initial public offering
in 2022, were made to conform to the disclosures made by similarly situated China-based companies listed in the United States.

In response to the Staff’s comments, the Company respectfully
advises the Staff that it proposes to revise the referenced disclosures as follows in the section of “Risks related to Doing Business
in China” in its 2024 Annual Report (with deletions shown as strike-through and additions underlined) and
conform such changes elsewhere in its 2024 Annual Report as applicable.

“(Page 29)

Risks Related to Doing Business in China

Changes in China’s economic, political or social conditions
or government policies could have a material adverse effect on our business, financial condition and results of operations.

We conduct all of our operations in China and all of our revenue is
derived from our operations in China. Accordingly, our results of operations and prospects are, to a significant degree, subject to economic,
political and legal developments in China. The economy of China differs from the economies of most developed countries in ma