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                                                           March 4, 2026

Jonathan Stanner
Chief Executive Officer
Summit Hotel Properties, Inc.
13215 Bee Cave Parkway, Suite B-300
Austin, TX 78738

       Re: Summit Hotel Properties, Inc.
           Registration Statement on Form S-3
           Filed February 25, 2026
           File No. 333-293752
Dear Jonathan Stanner:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Stacie Gorman at 202-551-3585 with any questions.

                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:    Mollie Duckworth, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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Document

Summit Hotel Properties, Inc.

13215 Bee Cave Parkway, Suite B-300

Austin, Texas 78738

March 4, 2026

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Stacie Gorman

Re:  Summit Hotel Properties, Inc.

  Registration Statement on Form S-3

Filed February 25, 2026

  File No. 333-293752

Dear Ms. Gorman:

In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, Summit Hotel Properties, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-3 (File No. 333-293752) (as amended, the “Registration Statement”). The Company respectfully requests that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on March 6, 2026 or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Mollie Duckworth of Latham & Watkins LLP at (737) 910-7325.

  Very truly yours,

  SUMMIT HOTEL PROPERTIES, INC.

  /s/ Christopher Eng

  Christopher Eng

  Executive Vice President, General Counsel, Chief Risk Officer and Secretary

cc: Mollie Duckworth, Latham & Watkins LLP

 Cathy A. Birkeland, Latham & Watkins LLP

 Julian T.H. Kleindorfer, Latham & Watkins LLP

United States securities and exchange commission logo
May 26, 2021
Christopher Eng
Executive Vice President and General Counsel
Summit Hotel Properties, Inc.
13215 Bee Cave Parkway, Suite B-300
Austin, TX 78738
Re:Summit Hotel Properties, Inc.
Form 10-K for the fiscal year ended December 31, 2020
Filed February 26, 2021
File No. 001-35074
Dear Mr. Eng:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

CORRESP
1
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    13215
    Bee Cave Parkway, Suite B-300

    Austin,
    Texas 78738

    Office:
    (512) 538-2300

    www.shpreit.com

May 25, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Real Estate & Construction

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Ms. Shannon Menjivar

Attention: Mr. Jeffrey Lewis

RE:         Summit
Hotel Properties, Inc.

Form 10-K for the fiscal year ended December 31,
2020

Filed February 26, 2021

File No. 001-35074

Dear Ms. Menjivar and Mr. Lewis:

This letter is being submitted in response to
the comment letter dated May 21, 2021 of the staff of the Division of Corporate Finance (the “Staff”) of the United
States Securities and Exchange Commission (the “SEC”) regarding the Form 10-K for the fiscal year ended December 31,
2020 filed by Summit Hotel Properties, Inc. (the “Company”) on February 26, 2021.

For the Staff’s convenience, the Staff’s
comment appears below in italics with the Company’s response to the comment set out immediately below it.

Form 10-K for the fiscal year ended December 31, 2020

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

Non-GAAP Financial Measures, page 49.

1. We note your response to comment 1. As the provision for credit losses does not appear to be
                                 an impairment charge we do not believe the FFO measure, as presented, meets the NAREIT definition. Please
                                 revise the caption of the measure or remove the adjustment to arrive at FFO. In addition, the adjustment
                                 does not appear to be consistent with your definition of EBITDAre and may be more consistent with your
                                 definition of Adjusted EBITDAre. Please revise or advise.

1│ Page

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Real Estate & Construction

May 25, 2021

RESPONSE:

In response to the Staff’s comment, for
all future filings with the SEC, we will remove the adjustment for provision for credit losses from our calculations of funds from operations
(“FFO”) and earnings before income taxes, depreciation and amortization for real estate (“EBITDAre”).
We will instead include those adjustments only in our calculations of adjusted FFO (“AFFO”) and adjusted EBITDAre.
In both cases, we will include appropriate disclosures of our calculations of AFFO and adjusted EBITDAre such that our rationale
for including such adjustments in those non-GAAP financial measures is clear.

We have reviewed the Staff’s comment and
this response with our Audit Committee. If you have any questions or comments regarding our response above, please do not hesitate to
call the undersigned at 512-538-2302.

    Very truly yours,

    /s/ Jonathan P.
    Stanner

    Jonathan P. Stanner

    President & Chief Executive Officer

Cc:         Christopher
R. Eng, General Counsel & Chief Risk Officer

David C. Wright, Hunton Andrews Kurth LLP

Mark W. Wickersham, Hunton Andrews Kurth LLP

2│Page

United States securities and exchange commission logo
May 21, 2021
Christopher Eng
Executive Vice President and General Counsel
Summit Hotel Properties, Inc.
13215 Bee Cave Parkway, Suite B-300
Austin, TX 78738
Re:Summit Hotel Properties, Inc.
Form 10-K for the fiscal year ended December 31, 2020
Filed February 26, 2021
File No. 001-35074
Dear Mr. Eng:
            We have reviewed your May 4, 2021 response to our comment letter 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 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
April 28, 2021 letter.
Form 10-K for the fiscal year ended December 31, 2020
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 49
1.We note your response to comment 1. As the provision for credit losses does not appear to
be an impairment charge we do not believe the FFO measure, as presented, meets the
NAREIT definition. Please revise the caption of the measure or remove the adjustment to
arrive at FFO. In addition, the adjustment does not appear to be consistent with your
definition of EBITDAre and may be more consistent with your definition of Adjusted
EBITDAre. Please revise or advise.

 FirstName LastNameChristopher  Eng
 Comapany NameSummit Hotel Properties, Inc.
 May 21, 2021 Page 2
 FirstName LastName
Christopher  Eng
Summit Hotel Properties, Inc.
May 21, 2021
Page 2
            You may contact Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or Shannon
Menjivar, Accounting Branch Chief, at (202) 551-3856 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

CORRESP
1
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    13215
                                            Bee Cave Parkway, Suite B-300

Austin,
Texas 78738

Office:
(512) 538-2300

www.shpreit.com

May 4, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Real Estate & Construction

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Ms. Shannon Menjivar

Attention: Mr. Jeffrey Lewis

 RE: Summit Hotel Properties, Inc.

Form 10-K for the fiscal year
ended December 31, 2020

Filed February 26, 2021

File No. 001-35074

Dear Ms. Menjivar & Mr. Lewis:

This letter is being submitted in response
to the comment letter dated April 28, 2021 of the staff of the Division of Corporate Finance (the “Staff”) of the United
States Securities and Exchange Commission (the “SEC”) regarding the Form 10-K filed by Summit Hotel Properties, Inc.
(the “Company”) on February 26, 2021.

For the Staff’s convenience, the
Staff’s comment appears below in italics with the Company’s response to the comment set out immediately below it.

Form 10-K for the fiscal year ended December 31,
2020

Item 7. Management’s Discussion and Analysis
of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 49

 1. We note a provision for credit losses of $4.8 million for
the year ended December 31, 2020, which is presented as an adjustment from Net (loss) income to FFO applicable to common shares
and common units and further adjusted to arrive at EBITDAre. We also note in your earnings release a provision for credit losses of $2.3
million and $4.8 million for the three and twelve months ended December 31, 2020, respectively, which is included in your presentation
of Hotel EBITDA. Please tell us how you determined these adjustments were appropriate and if you intend to make similar adjustments to
these non-GAAP measures going forward.

    1 | Page

Ms. Shannon Menjivar

Mr. Jeffrey Lewis

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Real Estate & Construction

May 4, 2021

RESPONSE:

As defined by Nareit, FFO represents
net income or loss (computed in accordance with GAAP), excluding preferred dividends, gains (or losses) from sales of real property, impairment
losses on real estate assets, items classified by GAAP as extraordinary, the cumulative effect of changes in accounting principles, plus
depreciation and amortization related to real estate assets, and adjustments for unconsolidated partnerships, and joint ventures. EBITDAre,
as defined by Nareit, is calculated as EBITDA, excluding: (i) loss and gains on disposition of property and (ii) asset impairments,
if any.

Our provision for credit losses represents
an infrequently occurring, non-cash charge to reduce the net carrying amounts of the related real estate notes receivables to their estimated
net realizable amounts at the reporting date. The provision for credit losses referenced in your letter relate to certain of our real
estate notes receivables, which are qualified real estate assets for real estate investment trusts. We view the provision for credit losses
as similar in nature to an impairment charge for our other real estate assets, such as hotel properties. Therefore, we believe that adjusting
Net (loss) income to FFO applicable to common shares and common units and further adjusted to arrive at EBITDAre for the provision for
credit losses provides a consistent presentation of FFO and EBITDAre based on the Nareit definitions and industry practice. Additionally,
if any portion of the provision for credit losses is reversed in future periods as a result of our determination that there has been an
increase in the expected recoverability of the notes receivables (not to exceed the aggregate of amounts previously written off and expected
to be written off), we would also adjust Net (loss) income for the reversal of the provision for credit losses to calculate FFO applicable
to common shares and common units and EBITDAre.

We present Hotel EBITDA as an additional
non-GAAP financial measure to provide investors a more complete understanding of the operating results over which individual hotels and
operators have direct control. The provision for credit losses of $2.3 million and $4.8 million for the three and twelve months ended
December 31, 2020, respectively, do not relate to hotel operations and such credit losses were not under the control of our individual
hotels or operators. Therefore, we believe adding back the provision for credit losses to our consolidated operating income (loss) reported
on a GAAP basis in our calculation of Hotel EBITDA is appropriate.

    2 | Page

Ms. Shannon Menjivar

Mr. Jeffrey Lewis

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Real Estate & Construction

May 4, 2021

Our real estate notes receivables, in
part, relate to mezzanine loans for real estate development projects used to fund the development of hotel properties. The mezzanine
loans generally have separate options that enable us to purchase the hotel property upon completion of the construction. Mezzanine loan
transactions generally comprise a limited part of our investment strategy, if and when such an opportunity arises and meets our underwriting
standards. Mezzanine loans are not core to our business. As of December 31, 2020, the gross amount of our notes receivables related
to mezzanine loans was $28.7 million, or approximately 1% of total assets, and we recorded a provision for credit losses related to certain
of these loans totaling $2.5 million during the first quarter of 2020, primarily as a result of the negative effects of the COVID-19
pandemic on the borrowers. The mezzanine loans outstanding at December 31, 2020 mature on various dates between March 2022
and May 2022. We currently do not have new mezzanine loans planned or in process. Therefore, similar adjustments to these non-GAAP
measures going forward will only be required for a limited time through the maturity dates of our currently outstanding mezzanine loans
and only if we determine in a future reporting period prior to the maturity dates of the loans that the net realizability of the loans
is less than their net carrying amounts thereby requiring a provision for credit losses. However, if new mezzanine loans are closed in
the future and ever require a provision for credit losses, we would anticipate making similar adjustments to these non-GAAP financial
measures so that we can provide investors with a more complete understanding of our operating results and to ensure consistency in our
reporting of non-GAAP financial measures between periods and comparability in our reporting of non-GAAP measures among our peer companies.

In addition, our real estate notes receivables
also relate to seller-financing loans that we received as consideration for a portion of the sale of two hotel properties to a single
purchaser in 2018. The gross outstanding balance of these loans was $2.4 million at December 31, 2020 and the loans are scheduled
to mature on December 31, 2021. We generally do not provide seller-financing when selling hotel properties; however, we provided
such financing for this sale on an exception basis to facilitate the transaction. During the fourth quarter of 2020, the borrower failed
to make scheduled payments under the terms of the loan agreements as a result of the negative effects of the COVID-19 pandemic on the
borrower. We have been in negotiations with the borrower to secure repayment of the outstanding balance and unpaid interest on the loans.
However, we are uncertain as to whether we will be successful in our negotiations with the borrower to secure repayment of the outstanding
obligations. As such, we recorded a $2.3 million provision for credit losses during the three months ended December 31, 2020, which
is equal to the balance of the loans net of a discount on the loans of $0.1 million. Given that the loans are fully reserved, no additional
provision for credit losses is possible. If we are able to secure repayment of some or all of the balance of the outstanding obligations,
then we will reverse the provision for credit losses related to these loans in an amount equal to our recovery under the loans. Since
the provision for credit losses related to these loans is an infrequent and non-recurring, non-cash item, and does not relate to the operating
results of the hotels or operators, we believe the adjustment to adjust Net (loss) income for the provision for credit losses to calculate
Hotel EBITDAre is appropriate to ensure consistency in our reporting of non-GAAP financial measures between periods and comparability
in our reporting of non-GAAP measures among our peer companies.

    3 | Page

Ms. Shannon Menjivar

Mr. Jeffrey Lewis

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Real Estate & Construction

May 4, 2021

We have reviewed the Staff’s comment
letter and this response with our Audit Committee. If you have any questions or comments regarding our response above, please do not hesitate
to call the undersigned at 512-538-2302.

    Very
    truly yours,

    /s/
    Jonathan P. Stanner

    Jonathan
    P. Stanner

    President &
    Chief Executive Officer

 Cc: Christopher R. Eng, General Counsel & Chief Risk Officer

David C. Wright, Hunton, Andrews, Kurth,
LLP

Mark W. Wickersham, Hunton, Andrews,
Kurth, LLP

    4 | Page

United States securities and exchange commission logo
April 28, 2021
Christopher Eng
Executive Vice President and General Counsel
Summit Hotel Properties, Inc.
13215 Bee Cave Parkway, Suite B-300
Austin, TX 78738
Re:Summit Hotel Properties, Inc.
Form 10-K for the fiscal year ended December 31, 2020
Filed February 26, 2021
File No. 001-35074
Dear Mr. Eng:
            We have reviewed your filing 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 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2020
Item 7. Managements Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures , page 49
1.We note a provision for credit losses of $4.8 million for the year ended December 31,
2020, which is presented as an adjustment from Net (loss) income to FFO applicable to
common shares and common units and further adjusted to arrive at EBITDAre.  We also
note in your earnings release a provision for credit losses of $2.3 million and $4.8 million
for the three and twelve months ended December 31, 2020, respectively, which is
included in your presentation of Hotel EBITDA.  Please tell us how you determined
these adjustments were appropriate and if you intend to make similar adjustments to these
non-GAAP measures going forward.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameChristopher  Eng
 Comapany NameSummit Hotel Properties, Inc.
 April 28, 2021 Page 2
 FirstName LastName
Christopher  Eng
Summit Hotel Properties, Inc.
April 28, 2021
Page 2
            You may contact Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or Shannon
Menjivar, Accounting Branch Chief, at (202) 551-3856 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

Mail Stop 3233
October 1 7, 2017

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 fis cal year ended December 31, 2016
Filed February 23, 2017
Form 8 -K
Filed August 2, 2017
File No. 001-35074

Dear Mr. Dowell :

We have completed our review of your filings .  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence  of action  by the staff .

Sincerely,

 /s/ Kristi Marrone

Kristi Marrone
Staff Accountant
Office of Real Estate
& Commodities

CORRESP
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		Document

 12600 Hill  Country Boulevard
Suite R - 100
A us t i n, Texas  78738
512-538-2300

October 3, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporate Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention:  Ms. Kristi Marrone

RE:

 Summit Hotel Properties, Inc.

Form 8-K

Filed August 2, 2017

File No. 001-35074

Dear Ms. Marrone:

This letter is being submitted in response to the comment letter dated September 21, 2017 of the staff of the Division of Corporate Finance (the “Staff”) of the United States Securities and Exchange Commission (the “SEC”) regarding the Current Report on Form 8-K filed by Summit Hotel Properties, Inc. (the “Company”) on August 2, 2017.

For the Staff’s convenience, the Staff’s comment appears below in italics with the Company’s response to the comment set out immediately below it.

Form 8-K filed August 2, 2017

Exhibit 99.1

Pro Forma Operational and Statistical Data, page 14

1.

 We note that your presentation of Hotel EBITDA on a pro forma basis.  In future filings, please revise your presentation of Hotel EBITDA as follows:

a.

 Reconcile to the most directly comparable GAAP financial measure in accordance with Regulation G and Item 10(e)(1)(i) of Regulation S-K.

b.

 Present Actual Hotel EBITDA, followed by a single adjustment for pre- acquisition results to arrive at Pro Forma Hotel EBITDA.  Present other pro forma line items (e.g. pro forma revenues and hotel operating expenses) in a similar manner if you wish to continue to present those measures.

c.

 Describe the source of pre-acquisition results and any adjustments made to those results.  Additionally, consider disclosing whether the pre-acquisition results were audited or reviewed by your auditors.

d.

 To the extent that you continue to present Pro Forma Total Revenue or other measures that include pre-acquisition results, tell us how you considered providing the relevant non-GAAP measures.

Ms. Kristi Marrone

United States Securities and Exchange Commission

Division of Corporate Finance

October 3, 2017

RESPONSE:

(1)In future filings, we will revise our presentation of Hotel EBITDA and Pro Forma Hotel EBITDA as described in the following paragraphs (a) through (d). To illustrate how the proposed reconciliations and additional disclosures will appear in our future filings, we have prepared a schedule of Pro Forma Hotel Operating Data populated with data for the three- and six-month periods ended June 30, 2016 and 2017. This illustrative schedule is Attachment A to this response letter (“Attachment A”).

(a)As illustrated in Attachment A, we will reconcile Pro Forma Hotel EBITDA to Operating Income, which is the most directly comparable GAAP financial measure, in accordance with Regulation G and Item 10(e)(1)(i) of Regulation S-K.

(b)As illustrated in Attachment A, we will present Actual Hotel EBITDA, followed by adjustments for pre-acquisition and pre-disposition results, to arrive at Pro Forma Hotel EBITDA. Additionally, as illustrated in Attachment A, we will reconcile Pro Forma Total Revenues and Pro Forma Total Hotel Operating Expenses to Total Revenues and Total Hotel Operating Expenses, respectively, which are the most directly comparable GAAP financial measures.

(c)As illustrated in Attachment A, we will include footnotes to the schedule of Pro Forma Hotel Operating Data that will (i) describe the source of pre-acquisition results, (ii) indicate whether adjustments have been made to such results, and (iii) state whether such results have been audited or reviewed by our auditors.

(d)Pro Forma Total Revenues and other measures that include pre-acquisition results are included in our presentation of non-GAAP measures to enable comparison of financial results for the current period to financial results of the corresponding period of the prior year.  This comparison necessitates the inclusion or exclusion of pre-acquisition or pre-disposition financial results, respectively, and is consistent with presentations of other similar companies in our industry.

Ms. Kristi Marrone

United States Securities and Exchange Commission

Division of Corporate Finance

October 3, 2017

If you have any questions or comments regarding our response above, please do not hesitate to call the undersigned at 512-538-2303.

Very truly yours,

/s/ Greg A. Dowell

Greg A. Dowell

Executive Vice President

and Chief Financial Officer

Cc:    Daniel P. Hansen, Chief Executive Officer

Christopher R. Eng, General Counsel and Chief Risk Officer

David C. Wright, Hunton & Williams, LLP

Mark W. Wickersham, Hunton & Williams, LLP

ATTACHMENT A

SUMMIT HOTEL PROPERTIES, INC.

Pro Forma Hotel Operating Data

Schedule of Property Level Results

(Unaudited)

 For the Three Months Ended June 30,

 For the Six Months Ended June 30,

Pro Forma Operating Data (1) (2)

 2017

 2016

 2017

 2016

Pro forma room revenue

 $

 131,101

 $

 134,266

 $

 252,940

 $

 254,101

Pro forma other hotel operations revenue

 9,729

 10,306

 18,810

 19,971

Pro forma total revenues

 140,830

 144,572

 271,750

 274,072

Pro forma total hotel operating expenses

 86,191

 85,380

 168,362

 165,021

Pro forma hotel EBITDA

 $

 54,639

 $

 59,192

 $

 103,388

 $

 109,051

Pro forma hotel EBITDA Margin

 38.8

 %

 40.9

 %

 38.0

 %

 39.8

 %

Reconciliations of Non-GAAP financial measures to comparable GAAP financial measures

Revenue:

Total revenues

 $

 129,056

 $

 127,195

 $

 247,045

 $

 245,277

Total revenues from acquisitions (1)

 13,656

 27,369

 32,992

 51,294

Total revenues from dispositions (2)

 (1,882

 )

 (9,992

 )

 (8,287

 )

 (22,499

 )

Pro forma total revenues

 $

 140,830

 $

 144,572

 $

 271,750

 $

 274,072

Hotel Operating Expenses:

Total hotel operating expenses

 $

 79,499

 $

 76,757

 $

 154,703

 $

 150,895

Total hotel operating expenses from acquisitions (1)

 8,183

 15,662

 19,779

 30,037

Total hotel operating expenses from dispositions (2)

 (1,491

 )

 (7,039

 )

 (6,120

 )

 (15,911

 )

Pro forma total hotel operating expenses (1) (2)

 $

 86,191

 $

 85,380

 $

 168,362

 $

 165,021

Hotel EBITDA:

Operating income

 $

 24,515

 $

 25,634

 $

 43,082

 $

 46,302

Hotel property acquisition costs

 —

 1,728

 354

 2,282

Corporate general and administrative expenses

 5,310

 5,391

 10,448

 9,970

Depreciation and amortization

 19,732

 17,685

 38,458

 35,828

Hotel EBITDA

 49,557

 50,438

 92,342

 94,382

Hotel EBITDA from acquisitions (1)

 5,473

 11,707

 13,213

 21,257

Hotel EBITDA from dispositions (2)

 (391

 )

 (2,953

 )

 (2,167

 )

 (6,588

 )

Pro forma hotel EBITDA

 $

 54,639

 $

 59,192

 $

 103,388

 $

 109,051

(1)

 Pro forma information includes operating results for 81 hotels owned as of June 30, 2017 as if all such hotels had been owned by the Company since January 1, 2016.  For hotels acquired by the Company after January 1, 2016 (the “Acquired Hotels”), the Company has included in the pro forma information the financial results of each of the Acquired Hotels for the period from January 1, 2016 to the date the Acquired Hotels were purchased by the Company (the “Pre- acquisition Period”).  The financial results for the Pre-acquisition Period were provided by the third-party owner of such Acquired Hotel prior to purchase by the Company and have not been audited or reviewed by our auditors or adjusted by us.   The pro forma information is included to enable comparison of results for the current reporting period to results for the comparable period of the prior year and are not indicative of future results.

(2)

 For hotels sold by the Company between January 1, 2016 and June 30, 2017 (the “Disposed Hotels”), the pro forma information excludes the financial results of each of the Disposed Hotels for the period of ownership by the Company from January 1, 2016 through the date that the Disposed Hotels were sold by the Company.

ATTACHMENT A (continued)

SUMMIT HOTEL PROPERTIES, INC.

Pro Forma Hotel Operating Data

Schedule of Property Level Results

(Unaudited)

 2016

 2017

 Trailing Twelve

Months Ended

June 30, 2017

Pro Forma Operating Data (1) (2)

 Q3

 Q4

 Q1

 Q2

Pro forma room revenue

 $

 126,811

 $

 114,088

 $

 121,839

 $

 131,101

 $

 493,839

Pro forma other hotel operations revenue

 9,946

 8,630

 9,082

 9,729

 37,387

Pro forma total revenues

 136,757

 122,718

 130,921

 140,830

 531,226

Pro forma total hotel operating expenses

 83,771

 77,787

 82,172

 86,191

 329,921

Pro forma hotel EBITDA

 $

 52,986

 $

 44,931

 $

 48,749

 $

 54,639

 $

 201,305

Pro forma hotel EBITDA Margin

 38.7

 %

 36.6

 %

 37.2

 %

 38.8

 %

 37.9

 %

Pro Forma Statistics (1) (2)

Rooms occupied

 850,499

 788,526

 803,388

 869,275

 3,311,688

Rooms available

 1,067,292

 1,067,292

 1,044,720

 1,056,325

 4,235,629

Occupancy

 79.7

 %

 73.9

 %

 76.9

 %

 82.3

 %

 78.2

 %

ADR

 $

 149.10

 $

 144.69

 $

 151.66

 $

 150.82

 $

 149.12

RevPAR

 $

 118.82

 $

 106.89

 $

 116.62

 $

 124.11

 $

 116.59

Actual Statistics

Rooms occupied

 775,529

 737,390

 761,358

 813,577

 3,087,854

Rooms available

 983,579

 1,002,482

 990,913

 986,998

 3,963,972

Occupancy

 78.8

 %

 73.6

 %

 76.8

 %

 82.4

 %

 77.9

 %

ADR

 $

 142.84

 $

 139.16

 $

 144.94

 $

 148.13

 $

 143.87

RevPAR

 $

 112.63

 $

 102.36

 $

 111.36

 $

 122.10

 $

 112.07

Reconciliations of non-GAAP financial measures to comparable GAAP financial measures

Revenue:

Total revenues

 $

 118,336

 $

 110,322

 $

 117,989

 $

 129,056

 $

 475,703

Total revenues from acquisitions (1)

 25,130

 18,479

 19,336

 13,656

 76,601

Total revenues from dispositions (2)

 (6,709

 )

 (6,083

 )

 (6,404

 )

 (1,882

 )

 (21,078

 )

Pro forma total revenues

 $

 136,757

 $

 122,718

 $

 130,921

 $

 140,830

 $

 531,226

Hotel Operating Expenses:

Total hotel operating expenses

 $

 73,530

 $

 71,256

 $

 75,204

 $

 79,499

 $

 299,489

Total hotel operating expenses from acquisitions (1)

 15,030

 10,994

 11,596

 8,183

 45,803

Total hotel operating expenses from dispositions (2)

 (4,789

 )

 (4,463

 )

 (4,628

 )

 (1,491

 )

 (15,371

 )

Pro forma total hotel operating expenses

 $

 83,771

 $

 77,787

 $

 82,172

 $

 86,191

 $

 329,921

Hotel EBITDA:

Operating income

 $

 21,427

 $

 14,758

 $

 18,567

 $

 24,515

 $

 79,267

Loss on impairment of assets

 577

 —

 —

 —

 577

Hotel property acquisition costs

 527

 683

 354

 —

 1,564

Corporate general and administrative expenses

 4,388

 4,934

 5,138

 5,310

 19,770

Depreciation and amortization

 17,887

 18,691

 18,726

 19,732

 75,036

Hotel EBITDA

 44,806

 39,066

 42,785

 49,557

 176,214

Hotel EBITDA from acquisitions (1)

 10,100

 7,485

 7,740

 5,473

 30,798

Hotel EBITDA from dispositions (2)

 (1,920

 )

 (1,620

 )

 (1,776

 )

 (391

 )

 (5,707

 )

Pro forma hotel EBITDA

 $

 52,986

 $

 44,931

 $

 48,749

 $

 54,639

 $

 201,305

(1)

 Pro forma information includes operating results for 81 hotels owned as of June 30, 2017 as if all such hotels had been owned by the Company since July 1, 2016.  For hotels acquired by the Company after July 1, 2016 (the “Acquired Hotels”), the Company has included in the pro forma information the financial results of each of the Acquired Hotels for the period from July 1, 2016 to the date the Acquired Hotels were purchased by the Company (the “Pre-acquisition Period”).  The financial results for the Pre-acquisition Period were provided by the third-party owner of such Acquired Hotel prior to purchase by the Company and have not been audited or reviewed by our auditors or adjusted by us.   The pro forma information is included to enable comparison of results for the current reporting period to results for the comparable period of the prior year and are not indicative of future results.

(2)

 For hotels sold by the Company between July 1, 2016 and June 30, 2017 (the “Disposed Hotels”), the pro forma information excludes the financial results of each of the Disposed Hotels for the period of ownership by the Company from July 1, 2016 through the date that the Disposed Hotels were sold by the Company.

Mail Stop 3233

September 21, 2017

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 fis cal year ended December 31, 2016
Filed February 23, 2017
Form 8 -K
Filed August 2, 2017
File No. 001-35074

Dear Mr. Dowell :

We have reviewed your filing s 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 advis e us as soon as possible  when you will respond.  If you  do not believe our
comment applies  to your facts and circumstances , please tell us why in your response.

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

Form 8 -K filed August 2, 2017

Exhibit 99.1

Pro Forma Operational and Statistical Data, page 14
1. We note your presentation of Hotel EBITDA on a pro forma basis. In future filings,
please revise your presentation of Hotel EBITDA as follows:
a. Reconcile to the most directly compara ble GAAP financial measure in
accordance with Regulation G and Item 10(e)(1)(i) of Regulation S -K.
b. Present Actual Hotel EBITDA, followed by a single adjustment for pre -
acquisition results to arrive at Pro Forma Hotel EBITDA.   Present other pro

Greg A. Dowell
Summit Hotel Properties, Inc.
September 21, 2017
Page 2

 forma line items (e.g. pro forma revenues and hotel operating expenses) in a
similar manner if you wish to continue to present those measures.
c. Describe the source of pre -acquisition results and any adjustments made to
those results. Additionally, consider disclosing whether the pre -acquisition
results were audited or reviewed by your auditors.
d. To the extent that you continue to present Pro Forma Total Revenue or other
measures that include pre -acquisition results, tell us how you considered
providing the relevant non -GAAP disclosures.
Please provide us with your proposed disclosure in your response.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absen ce of
action by the staff.

You may contact William Demarest, Staff Accounta nt at 202-551-3432  or me at 202-
551-3429 with any questions.

Sincerely,

 /s/ Kristi Marrone

Kristi Marrone
Staff Accountant
Office of Real Estate
& Commodities

Mailstop 3233
August 28, 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 -35074

Dear Mr. Dowell:

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission o r any person under the
federal securities laws of the United States.  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 o f 1934 and all applicable rules require.

Sincerely,

 /s/ Daniel L. Gordon

Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities

CORRESP
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12600   Hill Country Boulevard

Suite R-100

Austin,   Texas 78738

512-538-2300

August 14, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporate Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention:  Mr. Daniel Gordon

RE:                          Summit Hotel Properties, Inc.

Form 10-K for the Year Ended December 31, 2014

Filed March 2, 2015

File No. 1-9044

Dear Mr. Gordon:

This letter is being submitted in response to the comment letter of the staff of the Division of Corporate Finance (the “Staff”) of the United States Securities and Exchange Commission (the “SEC”) regarding the above-referenced Annual Report on Form 10-K filed by Summit Hotel Properties, Inc. (the “Company”).

For the Staff’s convenience, the Staff’s comment appears below in italics with the Company’s response to the comment set out immediately below it.

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 represents FFO attributable to common shareholders and OP unitholders. Please revise your presentation in future filings to clearly label such measure.

RESPONSE: For future SEC filings beginning with the Company’s Quarterly Report on Form 10-Q for the quarter ending September 30, 2015, the Company will clearly indicate that its FFO is applicable to common shareholders and OP unitholders and that its reconciliation of FFO begins with the Company’s GAAP net income or loss applicable to common shareholders and OP unitholders.

The Company hereby acknowledges that:

·                  the Company is responsible for the adequacy and accuracy of the disclosure in its filings;

·                  Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Company’s filings;

·                  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.

This response has been shared with our Audit Committee and they concur with the Company’s response.

If you have any questions or comments regarding our response above, please do not hesitate to call the undersigned at 512-538-2303.

Very truly yours,

/s/ Greg A. Dowell

Greg A. Dowell

Executive Vice   President and Chief Financial Officer

Cc:

Daniel P. Hansen, Chief   Executive Officer

Christopher R. Eng,   General Counsel and Chief Risk Officer

David Freed,   Hunton & Williams, LLP

2

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

July 21, 2014

Via E -mail
Mr. Paul Ruiz
Chief Accounting Officer
Interim Chief Financial Officer
Summit Hotel Properties, Inc.
12600 Hill Country Boulevard, Suite R -100
Austin, TX 78738

Re: Summit Hotel Properties, Inc.
Form 10 -K for the Year Ended December 31, 2013
Filed March 25, 2014
File No. 1-35074

Dear Mr. Ruiz :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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 securitie s laws of the United States.  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 rules require.

Sincerely,

 /s/ Jennifer Gowetski

Jennifer Gowetski
Senior Counsel

CORRESP
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12600   Hill Country Boulevard

Suite R-100

Austin,   Texas  78738

512-538-2300

July 2, 2014

VIA EDGAR AND FACSIMILE

United States Securities and Exchange Commission

Division of Corporate Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention:  Ms. Jennifer Gowetski

RE:                          Summit Hotel Properties, Inc.

Form 10-K for the Year Ended December 31, 2013

Filed March 25, 2014

File No. 1-35074

Dear Ms. Gowetski:

This letter is being submitted in response to the comment communicated on June 26, 2014 by the staff of the Division of Corporate Finance (the “Staff”) of the United States Securities and Exchange Commission (the “SEC”) regarding the above-referenced Annual Report on Form 10-K filed by Summit Hotel Properties, Inc. (the “Company”).

For the Staff’s convenience, the Staff’s comment is paraphrased below in italics with the Company’s response to the comment set out immediately below it.

Form 10-K for the Year Ended December 31, 2013

Disclosure of non-GAAP measure for Funds From Operations (“FFO”)

The Staff notes that the Company does not include a discussion of FFO in the Management’s Discussion and Analaysis (the “MDA”) of its Annual Report on Form 10-K for the year ended December 31, 2013.  Please note whether FFO is an important non-GAAP measure used by the Company in the operation of its business that should be disclosed in accordance with SEC Regulation G and Item 10(e) of Regulation S-K.  If not, please explain why it is not considered an important non-GAAP measure of performance.  If it is considered an important non-GAAP measure, please indicate that such measure and related discussion will be included in the MDA of future filings of the Company’s Annual Report on Form 10-K.

RESPONSE: FFO is a measure adopted by the National Association of Real Estate Investment Trusts, Inc. (“NAREIT”) in 1991 in order to promote a supplemental industry-wide measure of REIT operating performance that would not have certain drawbacks associated with net income under generally accepted accounting principles.  The definition was clarified in 1995, 1999 and 2002.  The definition currently is as follows:

Funds From Operations means net income (computed in accordance with generally accepted accounting principles), excluding gains (or losses) from sales of property, plus depreciation and amortization, and after adjustments for unconsolidated partnerships and joint ventures.  Adjustments for unconsolidated partnerships and joint ventures will be calculated to reflect funds from operations on the same basis.

The Company has not previously reported FFO, after consultation with its legal and accounting advisors, because the metric is not required to be reported under Regulations S-K or S-X and because the Company’s calculation is not precisely in accordance with the NAREIT definition.  However, the Company does consider its measure of FFO to be an important non-GAAP metric related to the performance of its business.  As such, the Company will include the presentation of  its measure of FFO in its future filings beginning with the Quarterly Report on Form 10-Q for the quarter ended June 30, 2014.

Although many REITs commonly report FFO substantially in accordance with the NAREIT definition provided above, there is variation in the calculation of FFO within the industry.   The Company’s calculation of FFO varies from the NAREIT definition provided above related to depreciation and amortization.  The variation from the standard definition of FFO results in measures of FFO among companies in the industry that are not precisely comparable.

Our presentation of FFO will include appropriate discussion and cautionary statements concerning our calculation of FFO and presentation of  FFO as a non-GAAP measure in accordance with SEC Regulation G and Item 10(e) of Regulation S-K.  Furthermore, the Company will disclose that our calculation of FFO differs from the standard definition adopted by NAREIT and may differ from the calculation of FFO by other companies in our industry; and as such, our calculation of FFO may not be comparable to that of other companies in our industry.

2

The Company hereby acknowledges that:

·                  the Company is responsible for the adequacy and accuracy of the disclosure in its filings;

·                  Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Company’s filings;

·                  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.

If you have any questions or comments regarding our response above, please do not hesitate to call the undersigned at 512-538-2441.

Very   truly yours,

/s/   Paul Ruiz

Paul   Ruiz

Chief   Accounting Officer

Interim   Chief Financial Officer

Cc:        Daniel P. Hansen, Chief Executive Officer

Christopher R. Eng, General Counsel and Chief Risk Officer

Jennifer L. Larsen, Partner, Hagan Wilka & Archer, LLP

3

October 26, 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 completed our review of your filings.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not as sert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Daniel L. Gordon

 Daniel L. Gordon
    Branch Chief

CORRESP
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[SUMMIT HOTEL PROPERTIES, INC. LETTERHEAD]

October 24, 2012

VIA EDGAR

United States Securities and Exchange Commission
 Division of Corporation Finance
 100 F. Street, N.E.
 Washington, D.C. 20549
 Attn: Daniel L. Gordon, Branch Chief

Re:                             Summit Hotel Properties, Inc.
 Form 10-K for the Year Ended December 31, 2011
 Filed February 28, 2012
 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 Mr. Gordon:

This letter is being submitted in response to the comment letter dated October 17, 2012 from the staff of the Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) regarding the above-referenced Annual Reports on Form 10-K filed by Summit Hotel Properties, Inc. (the “Company”) and Summit Hotel OP, LP (the “Operating Partnership”).

For the Staff’s convenience, the Staff’s comments have been stated below in italics, with the Company’s and the Operating Partnership’s responses to a particular comment set out immediately underneath it.  The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs in the Staff’s comment letter.

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 commitments 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 stipulated 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 payments.

RESPONSE:  In future periodic filings, beginning with the Company’s and the Operating Partnership’s Quarterly Reports on Form 10-Q for the quarter ended September 30, 2012, the Company and the Operating Partnership will revise the tabular presentation of their contractual obligations to include interest commitments under their variable-rate interest-bearing debt in the contractual obligations table and will provide appropriate disclosure with respect to their assumptions of estimated variable rate interest payments.

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.

RESPONSE:  In future periodic filings, beginning with the Company’s and the Operating Partnership’s Quarterly Reports on Form 10-Q for the quarter ended September 30, 2012, the Company and the Operating Partnership will revise the consolidated statements of operations to present the expense related to share-based payment arrangements in the same line or lines as cash compensation paid to the same employees.

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 value 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 expected to be recognized.

RESPONSE:  In future periodic filings, beginning with the Company’s and the Operating Partnership’s Quarterly Reports on Form 10-Q for the quarter ended September 30, 2012, the Company and the Operating Partnership will include all disclosures required by ASC 718-10-50.

2

The Company hereby acknowledges that:

·                                          the Company is responsible for the adequacy and accuracy of the disclosure in its filings.

·                                          Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Company’s filings.

·                                          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.

The Operating Partnership hereby acknowledges that:

·                                          the Operating Partnership is responsible for the adequacy and accuracy of the disclosure in its filings.

·                                          Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Operating Partnership’s filings.

·                                          the Operating Partnership 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.

If you have any questions or comments regarding these responses, please do not hesitate to call the undersigned at (512) 538-2310.

Very   truly yours,

/s/   Troy L. Hester

Troy   L. Hester

Chief   Accounting Officer

3

cc:                                 Jonathan Wiggins, Staff Accountant

Daniel P. Hansen, President and Chief Executive Officer

Stuart J. Becker, Chief Financial Officer

Christopher R. Eng, General Counsel

4

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

CORRESP
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corresp

Summit Hotel Properties, Inc.

2701 South Minnesota Avenue, Suite 6

Sioux Falls, South Dakota 57105

February 4, 2011

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Summit Hotel Properties, Inc.

Registration Statement on Form S-11 (File No. 333-168686)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Summit Hotel Properties, Inc.
(the “Company”) hereby requests acceleration of effectiveness of the above-captioned Registration
Statement to 4:00 p.m. (NYT) on Tuesday, February 8, 2011, or as soon thereafter as practicable.

The Company acknowledges the following:

    •

    should the Securities and Exchange Commission (the “Commission”) or the staff, acting
pursuant to delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

    •

    the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the Company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

    •

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

The Company kindly requests notification of effectiveness by a telephone call to David C. Wright at
(804) 788-8638 and that effectiveness also be confirmed in writing.

    Very truly yours,

SUMMIT HOTEL PROPERTIES, INC.

    By:
    /s/ Christopher R. Eng

    Name:
    Christopher R. Eng

    Title:
    Vice President, General Counsel and
Secretary

CORRESP
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corresp

    Hunton & Williams LLP

Riverfront Plaza, East Tower

951 East Byrd Street

Richmond, Virginia 23219-4074

Tel     804 • 788• 8200

Fax     804 • 788 • 8218

File No: 77051.2

February 4, 2011

VIA EDGAR

Ms. Sonia Gupta Barros

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Summit Hotel Properties, Inc.

Amendment No. 4 to Registration Statement on Form S-11

Filed January 28, 2011

File No. 333-168686

Dear
Ms. Barros:

As counsel to, and on behalf of, Summit Hotel Properties, Inc., a Maryland corporation (the
“Company”), we are transmitting the Company’s response to the comment of the Staff of the Division
of Corporation Finance (the “Staff”) of the Securities and Exchange Commission contained in your
letter dated February 3, 2011, which comment is reproduced below in italics and is followed by the
corresponding response of the Company.

    1.

    We note that Morgan Keegan & Company, Inc. is one of the underwriters for your offering.
Please advise us whether you have considered the materiality of the following legal
proceedings against Morgan Keegan & Company, Inc. and their potential impact on Morgan
Keegan’s ability to carry out its obligations as an underwriter:

    •

    SEC Division of Enforcement matter: In the Matter of Morgan Asset Management, Inc.,
Morgan Keegan & Company, Inc., James C. Kelsoe, Jr., and Joseph Thompson Weller, CPA,
as described in the SEC News Digest, Issue 2010-62, April 7, 2010.

    •

    Financial Industry Regulatory Authority (FINRA) complaint: Morgan Keegan & Company,
Inc. Action, announced in a news release dated April 7, 2010.

    •

    Administrative proceeding by the states of Alabama, Kentucky, Mississippi and South
Carolina: In the Matter of Morgan Asset Management, Inc. et al., Joint Administrative
Proceeding, File Nos. SC-2010-0016 (Alabama), 2010-AH-021 (Kentucky), S-08-0050
(Mississippi) and 08011 (South Carolina).

Response: The Company advises the Staff that it has considered the materiality of the legal
proceedings referenced above and has determined that the referenced proceedings should not
impact the ability of Morgan Keegan & Company, Inc. (“Morgan Keegan”) to perform its
obligations as an underwriter. The Company made this determination after discussing these
proceedings with representatives of Morgan Keegan, including Morgan Keegan’s general
counsel, and after having received a letter from Morgan Keegan’s general counsel that
provided the Company with assurances that Morgan Keegan’s ability to serve as an underwriter
is unimpaired and that Morgan Keegan is fully licensed and adequately capitalized to act as
an underwriter in the offering.

Ms. Sonia Gupta Barros

United States Securities and Exchange Commission

Division of Corporation Finance

February 4, 2011

Page 2

If you have any questions or comments regarding the foregoing, or have additional questions or
comments, please contact the undersigned at (804) 788-8638 or David Freed at (804) 788-8524.

    Very truly yours,

    /s/ David C. Wright

    David C. Wright

    cc:

    Kristina Aberg

Kerry W. Boekelheide

Daniel P. Hansen

Christopher R. Eng

James E. Showen

Kevin L. Vold

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February 4, 2011

Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

    Re:

    Summit Hotels Properties, Inc.

Registration on Form S-11 (File No. 333-168686)

Ladies and Gentlemen:

     As underwriters of the proposed public offering of up to 23,000,000 shares of common stock of
Summit Hotel Properties, Inc. (the “Company”), we hereby join the Company’s request for
acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:00 p.m.
(NYT) on February 8, 2011, or as soon thereafter as is practicable.

     Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we
wish to advise you that we have effected the following distribution of the Company’s Preliminary
Prospectus dated January 28, 2011, through the date hereof:

     Preliminary Prospectus:

     Three thousand four hundred ninety (3,490) copies to prospective Underwriters, institutional
investors, dealers and others.

     We were advised on February 4, 2011 by the Corporate Financing Department of the Financial
Industry Regulatory Authority, Inc. that it has reviewed the proposed offering and that it has
determined to raise no objections with respect to the fairness and reasonableness of the
underwriting terms and arrangements of the offering.

     The undersigned advise that they have complied and will continue to comply with Rule
15c2-8 under the Securities Exchange Act of 1934.

[Signature Page follows]

    Very truly yours,

DEUTSCHE BANK SECURITIES INC.

ROBERT W. BAIRD & CO. INCORPORATED

RBC CAPITAL MARKETS, LLC

       As representatives of the several Underwriters

    By:
    DEUTSCHE BANK SECURITIES INC.

    By:

/s/ Jeremy Fox

    Name:
    Jeremy Fox

    Title:
    Managing Director

    By:

/s/ Frank Windels

    Name:
    Frank Windels

    Title:
    Director

    By:

ROBERT W. BAIRD & CO. INCORPORATED

    By:

/s/ Justin Glasgow

    Name:
    Justin Glasgow

    Title:
    Vice President

    By:
    RBC CAPITAL MARKETS, LLC

    By:

/s/ Scott M. Merkle

    Name:
    Scott M. Merkle

    Title:
    Director

[Signature Page to Acceleration Request]

February 3, 2011
 Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. 2701 South Minnesota Avenue, Suite 6 Sioux Falls, SD 57105
Re: Summit Hotel Properties, Inc.
Amendment No. 4 to Registrati on Statement on Form S-11
Filed January 28, 2011
  File No. 333-168686

Dear Mr. Hansen:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

 1. We note that Morgan Keegan & Company, In c. is one of the underwriters for your
offering.  Please advise us whether you have considered the materiality of the following
legal proceedings against Morgan Keegan & Company, Inc. and their potential impact on
Morgan Keegan’s ability to carry out  its obligations as  an underwriter:

• SEC Division of Enforcement matter:  In the Matter of Morgan Asset Management, Inc.,
Morgan Keegan & Company, Inc., James C. Kelsoe, Jr., and Joseph Thompson Weller,
CPA, as described in the SEC Ne ws Digest, Issue 2010-62, April 7, 2010.
1

• Financial Industry Regulatory Authority (FINRA) complaint:  Morgan Keegan &
Company, Inc. Action, announced in a news release dated April 7, 2010.2

1 Available on the SEC’s website at http://www.sec.gov/news/digest/2010/dig040710.htm .

Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. February 3, 2011 Page 2

• Administrative proceeding by the states of  Alabama, Kentucky, Mississippi and South
Carolina:  In the Matter of Morgan Asset Ma nagement, Inc. et. al., Joint Administrative
Proceeding, File Nos. SC-2010-0016 (Ala bama), 2010-AH-021 (Kentucky), S-08-0050
(Mississippi) and 08011 (South Carolina).
3

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
You may contact Eric McPhee, Staff Account ant, at (202) 551-3693 or Daniel Gordon,
Branch Chief, at (202) 551-3486 if you have que stions regarding comments on the financial
statements and related matters.  Please contac t Kristina Aberg, Attorney-Advisor, at (202) 551-
3404 or me at (202) 551-3655 with any other questions.
Sincerely,

Sonia Gupta Barros Special Counsel
 cc: David C. Wright, Esq.  Hunton & Williams LLP

2 Available on FINRA’s website at http://www.finra.org/Newsroom/ NewsReleases/2010/P121250 .

3 Available on various state websites such as at http://www.kfi.ky.gov/public/morgankeegan.htm .

January 27, 2011
 Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. 2701 South Minnesota Avenue, Suite 6 Sioux Falls, SD 57105
Re:  Summit Hotel Properties, Inc.
Amendment No. 1 to Registrati on Statement on Form S-11
Filed September 23, 2010 File No. 333-168686

Dear Mr. Hansen:
We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and circumstances
or do not believe an amendment is appropr iate, please tell us why in your response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

Distribution Policy, page 50

1. Please revise your disclosure throughout the document to refer to the correct pro rata
initial annual distri bution rate of $.50 per share.
2. We note your disclosure that you expect to  use existing cash, including proceeds from
this offering and the concurrent private pl acement, or borrow funds to fund any shortfall
in cash available for your ini tial annual distribution.  Pleas e specifically ad dress how you
intend to fund the shortfall, and disclose any other liquidity needs you intend to fund
using existing cash.  Please also address any material changes or anticipated material
changes in the predecessor’s cash from th e September 30, 2010 balance sheet to present,
including any potential payments of priority return distributions to holde rs of its Class A
and A-1 membership interests.  If you intend to disclose that you will use a credit facility
to fund the shortfall, or any other liquidity need, you must have a signed commitment for
that facility.  Additionally, it is  not appropriate to cite a pl anned future offering of your
securities as a source to addre ss the shortfall.  Please provide similar disclosure within
your discussion of liquidity and capital resources.

Mr. Daniel P. Hansen Summit Hotel Properties, Inc. January 27, 2011 Page 2

 3. Please revise your discussion of the material as sumptions used in your calculation of cash
available for distribution, at the top of page 52, to include an assumption that income and
cash flows from operations for the twelve months ended September 30, 2011 will be substantially the same as income and cash fl ows from operations for the twelve months
ended September 30, 2010, except for disclosed diffe rences, as this appears to be the key
assumption you are making.
4. Please revise your calculation of cash availabl e for distribution to include a provision for
cash flows from investing activitie s that is at least as great as the historical average of
capital expenditures on your 65 hotel properties,  or your anticipated capital expenditures
for the 12 months ended September 30, 2011, whic hever is greater.  To the extent you
anticipate using proceeds from  the offering, you may disclose that amount in a footnote
to the table.  To the extent you intend to  use other sources of cash to pay for such
expenditures, please show the full amount of such expenditures in the table, and an
offsetting amount disclosing the other currently  available source(s) of cash.  As noted
above, if you intend to disclose that you will use borrowings under your anticipated
$100.0 million senior secured revolving cred it facility, you must have a signed
commitment for that facility, and it is not a ppropriate to cite a future offering of your
securities as a source of funds.
5. Please tell us why you did not include the balloon payment due on your debt maturing
September 30, 2011 as a component of estimated  cash used in financing activities.
Liquidity and Capital Resources, page 66

6. We note your disclosure that through Janua ry 15, 2011, your predecessor has accrued and
unpaid priority returns on class A and A-1 me mbership interests of $5 million, subject to
the availability of cash, and th at it may not have available cash to pay these returns.
Please tell us whether any returns would be paya ble if the transaction were to be effective
today, and revise your disclo sure to address the likeli hood that any payments may
become due before the effective da te of your formation transactions.
Unaudited Pro Forma Condensed Consolidated Financial Statements, page F-1
7. Please tell us how you determined it wa s appropriate to exclude the $6 million
impairment related to land held for sale fr om your pro forma financial statements.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.

Mr. Daniel P. Hansen Summit Hotel Properties, Inc. January 27, 2011 Page 3

 Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;;
• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

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

Please refer to Rules 460 and 461 regarding re quests for acceleration. We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement. Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact me at (202)  551-3693 or Daniel Gordon at (202) 551-3486 if you have
questions regarding comments on th e financial statements and rela ted matters. Please contact
Kristina Aberg at (202) 551-3404 or Sonia Gupta Barros at ( 202) 551-3655 with any other
questions.
 Sincerely,

Eric McPhee Staff Accountant

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

        October 8, 2010  Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. 2701 South Minnesota Avenue, Suite 6 Sioux Falls, SD 57105
Re: Summit Hotel Properties, Inc.
Amendment No. 1 to Registrati on Statement on Form S-11
Filed September 23, 2010
  File No. 333-168686

Dear Mr. Hansen:

We have reviewed your registration stat ement and have the following comments.
In some of our comments, we may ask you to  provide us with information so we may
better understand your disclosure.
 Please respond to this letter by am ending your registration statement and
providing the requested information.  If you do not believe our comments apply to your
facts and circumstances or do not believe an amendment is appropriate, please tell us why
in your response.
 After reviewing any amendment to your registration statement and the
information you provide in response to th ese comments, we may have additional
comments.    General

 1. We have reviewed your response to commen t one of our letter dated September 8,
2010 and the supplemental materials pr ovided.  We note that you have only
provided supporting documents for some of th e studies and reports that you cite in
the prospectus.  Please provide us with c opies of any study or report that you cite
or on which you rely.  Clearly mark the materials to identify the portions that
support your disclosure.  We note the fo llowing statements by way of example
only:
• “We believe our hotels will experience significant revenue growth as lodging
industry fundamentals recover from the economic recession which caused
industry-wide RevPAR to suffer a combined 18.4% decline in 2008 and 2009, according to Smith Travel Research. Industry conditions have shown improvement during the first eight mont hs of 2010, with RevPAR growth across

Mr. Daniel P. Hansen
Summit Hotel Properties, Inc. October 8, 2010 Page 2
all segments of 4.0% as compared to the same period of 2009, according to Smith Travel Research,” page 4;
• “According to Lodging Econometrics, during the second quarter of 2010,
approximately 68,000 new hotel rooms were  under construction in the U.S., as
compared to approximately 242,000 room s under construction in the second
quarter of 2008, a decline of 72%,” page 5; and
• “…according to Bloomberg, upcoming maturities with approximately
$28.4 billion of hotel-related commercial mortgage-backed securities, or CMBS,
are scheduled to mature through 2013 and a significant number of additional maturities are expected between 2015 and 2017,” page 87.
 2. We note your response to comment three of our letter dated September 8, 2010.
Please tell us how the support you have provided us provides a basis for your
statement that you are a “l eading” hotel owner.
 Use of Proceeds, page 41

 3. Please add disclosure to this section that  explains that if you are unable to obtain
required lender consents with respect to  approximately $      million of
outstanding indebtedness that  you have not yet obtained, you may have to repay
all or a portion of this in debtedness with proceeds of this offering in order to
complete the formation transactions.
 Distribution Policy, page 45

4. Please revise your filing to remove any pr ojections related to your initial dividend
distribution, including the ta ble on page 47.  Due to the difficulty in predicting
future cash flows, it is not appropriate fo r owners of hotels, which are not leased
to unrelated third parties, to project an initial dividend distribution where there is
limited operating history, a change in fl ags or a change in the management
company.
 Management’s Discussion and Analysis and Results of Operations, page 51

 5. We have reviewed your response to comm ent 19 of our letter dated September 8,
2010.  Please disclose the amount of accrue d and unpaid priority returns on the
Class A and Class A-1 membership interest s through a recent pr acticable date and
any additional amounts you expect to pay though the closing date of the offering.
 Tax Protection Agreements, page 69

 6. Please revise your disclosure to quantif y, if practicable, th e maximum amount of
cash you may be obligated to pay out unde r the tax protection agreements.

Mr. Daniel P. Hansen
Summit Hotel Properties, Inc. October 8, 2010 Page 3  Franchise Agreements, page 91

Hotel Management Agreements, page 92
 7. We have reviewed your response to comm ent 24 of our letter dated September 8,
2010.  Please confirm that you will provi de greater details of your hotel
management agreements at such time as you have a clearer un derstanding of the
material terms of the agreements.  Please also disclose the terms of your franchise
agreements.

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
Act of 1933 and all applicable Securities Act rules require.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Notwithstanding our comments, in the ev ent you request acceleration of the
effective date of the pending registration st atement please provide a written statement
from the company acknowledging that:
• should the Commission or the staff, acti ng pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

• the action of the Commission or the staff,  acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy  and accuracy of the disclo sure in the filing; and

• the company may not assert staff comment s and the declaration of effectiveness
as a defense in any proceeding initiat ed by the Commission or any person under
the federal securities laws of the United States.

Please refer to Rules 460 and 461 regard ing requests for acceleration.  We will
consider a written request for acceleration of  the effective date of the registration
statement as confirmation of th e fact that those requesting acc eleration are aware of their
respective responsibilities unde r the Securities Act of 1933 a nd the Securities Exchange
Act of 1934 as they relate to the proposed public  offering of the securi ties specified in the
above registration statement.  Please allo w adequate time for us to review any
amendment prior to the requested effective da te of the registration statement.

Mr. Daniel P. Hansen
Summit Hotel Properties, Inc. October 8, 2010 Page 4
You may contact Eric McPhee, Staff A ccountant, at (202) 551-3693 or Daniel
Gordon, Branch Chief, at (202) 551-3486 if  you have questions regarding comments on
the financial statements and related matters .  Please contact Kristina Aberg, Attorney-
Advisor, at (202) 551-3404 or me at (202) 551-3655 with any other questions.

Sincerely,

Sonia Gupta Barros Special Counsel
 cc: David C. Wright, Esq.  Edward W. Elmore, Esq.  Hunton & Williams LLP

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    HUNTON & WILLIAMS LLP

    RIVERFRONT PLAZA, EAST TOWER

    951 EAST BYRD STREET

    RICHMOND, VIRGINIA 23219-4074

    TEL      804 • 788 • 8200

    FAX      804 • 788 • 8218

    FILE NO: 77051.2

September 22, 2010

VIA EDGAR

Ms. Kristina Aberg

Ms. Sonia Gupta Barros

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    RE:

    Summit Hotel Properties, Inc.

Amendment No. 1 to Registration Statement on Form S-11

Filed on September 22, 2010

File No. 333-168686

Dear Ms. Aberg:

As counsel to, and on behalf of, Summit Hotel Properties, Inc., a Maryland corporation (the
“Company”), we are transmitting for filing pursuant to the Securities Act of 1933, as amended (the
“Securities Act”), Pre-Effective Amendment No. 1 (“Amendment No. 1”) to the Company’s Registration
Statement on Form S-11 (File No. 333-168686) (the “Registration Statement”) and the Company’s
responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) contained in your letter dated September 8,
2010.

For convenience of reference, each Staff comment contained in your September 8, 2010 comment letter
is reprinted below in italics, numbered to correspond with the paragraph numbers assigned in your
letter, and is followed by the corresponding response of the Company.

We have provided to each of you a courtesy copy of this letter and two courtesy copies of Amendment
No. 1 filed by the Company on the date hereof, one copy of which has been marked to reflect changes
made to the Registration Statement filed with the Commission on August 9, 2010 (the “Blackline”).
The changes reflected in Amendment No. 1 have been made in response to the Staff’s comments and for
the purpose of updating and revising certain information in the Registration Statement. Unless
otherwise indicated, all page references in our responses refer to the pages of the Blackline.
Capitalized terms used and not otherwise defined in this response letter shall have the meanings
set forth in the Registration Statement.

Ms. Kristina Aberg

Ms. Sonia Gupta Barros

September 22, 2010

Page 2

General

    1.

    Please provide us with copies of any study or report that you cite or on which you rely.
Clearly mark the materials to identify the portions that support your disclosure. Please
confirm that any other industry reports or studies on which you rely were not prepared for you
and that you did not compensate the party that prepared these reports or studies.
Alternatively, please file the expert’s consent as an exhibit to the registration statement.

    RESPONSE: The Company is providing to the Staff on a supplemental basis the publicly
available third-party reports underlying the charts and industry data contained in Amendment
No. 1, marked to identify the portions corresponding to the Company’s disclosures in the
Registration Statement. The Company advises the Staff that the industry reports referenced
in the Registration Statement were not prepared specifically for the Company and the Company
did not compensate any third party that prepared the reports other than pursuant to the
payment of normal subscription fees required of subscribers generally.

    2.

    Please provide us with copies of all graphics, maps, photographs, and related captions or
other artwork, including logos that you intend to use in the prospectus.

    RESPONSE: The Company is providing copies of these materials to the Staff on a
supplemental basis.

    3.

    We note your use of the following factual assertions throughout the prospectus. The basis
for such factual assertions and for your management’s beliefs should be clear from the text of
the prospectus or supporting documentation should be provided to us. Please revise your
disclosure to address our concerns, or advise us as necessary. In providing support, clearly
mark the location of the information you believe is supportive of the statement referenced.
By way of example only, we note the following factual assertions:

    •

    “We are a ... leading hotel owner ....”

    •

    “The total number of hotels in the upscale and midscale without food and beverage
hotel segments ... is more than six times larger than the total number of hotels in the
luxury and upper upscale segments... We also believe that ... we will be the only
publicly traded REIT focused solely on these segments on a national basis.”

Ms. Kristina Aberg

Ms. Sonia Gupta Barros

September 22, 2010

Page 3

    •

    “Our hotels are located in markets with multiple demand generators in which we have
extensive experience and that have historically offered strong risk adjusted returns.”

    •

    “Our initial portfolio is composed of 46 seasoned hotels with established track
records and strong positions within their markets....”

    •

    “... our hotels’ competitive advantages in their respective markets....”

    •

    “Over the last twenty years, our market segments have demonstrated the strongest
compounded growth in demand of all segments of the lodging industry....”

    RESPONSE: Throughout Amendment No. 1, the Company has revised the disclosure to
address the Staff’s concerns. Specifically, the Company has added or revised disclosure on
pages 1 and 71 {leading hotel owner} and {strong risk-adjusted returns}; 1 and 73
{competitive advantages}; 5, 82 and 83 {strongest compounded growth}; and elsewhere in
response to the Staff’s comment. The Company is also providing to the Staff on a
supplemental basis the back-up support for disclosure on pages 1 and 71 {leading hotel
owner}, 76 {six times larger}, 2 and 71 {only public REIT with same focus} and 1 and 71
{multiple demand generators} marked to identify the portions that support the Company’s
disclosure in the Registration Statement.

    4.

    We note that you have not included any disclosure in response to Item 402(s) of Regulation
S-K. Please advise us of the basis for your conclusion that disclosure is not necessary and
describe the process you undertook to reach that conclusion.

    RESPONSE: The Company advises the Staff that the Company does not believe the
Company’s initial compensation policies and practices as they relate to risk management
practices and risk-taking incentives are reasonably likely to have a material adverse effect
on the Company. In reaching that conclusion, management of the Company evaluated the
Company’s compensation design and philosophy and concluded that the proposed base and
incentive compensation of its employees do not encourage excessive risk-taking
when considered with the limitations set forth in the Company’s other governance policies
and proposed practices, including REIT requirements, leverage policies and the form of the
Company’s expected corporate governance guidelines. Further, the Company reviewed the
vesting periods of the proposed option grants, the incentive structure for the 2011 bonus
payments for Messrs. Boekelheide, Hansen and Aniszewski and the uniformity of incentive
compensation structure and philosophy throughout the Company.

Ms. Kristina Aberg

Ms. Sonia Gupta Barros

September 22, 2010

Page 4

    5.

    Please tell us if any portion of the purchase price will represent a gain or a loss related
to the settlement of a pre-existing relationship, which should be accounted for separately
from the business combination. Refer to ASC 805-10-25-20 through 25-21 and ASC 805-10-55-20
through 55-23.

    RESPONSE: The Company believes that no portion of the purchase price will represent
a gain or a loss related to the settlement of a pre-existing relationship as there are no
related party contracts in place that are being settled in connection with the merger.
Therefore, no gain or loss will be recognized.

Prospectus Cover Page

    6.

    We note that you have omitted the price range on the cover page and throughout the prospectus
of this registration statement but have included a price range for this initial public
offering in the Form S-4 for Summit Hotel OP, LP, file number 333-168685. Please revise the
cover page and prospectus to provide the same price range as that provided in the Form S-4 or
tell us why you have omitted it here.

    RESPONSE: The Company advises the Staff that the Company and the underwriters have
not yet established a price range for the common stock in the initial public offering.
Summit Hotel OP, LP describes in its registration statement on Form S-4 (File No.
333-168685) (the “S-4 Registration Statement”) that the number of OP units issuable in the
proposed merger was based on an assumed value of $15.00 per OP unit, which was the midpoint
of an assumed price range for a share of Company common stock determined at the time the
terms of the merger were finalized. As a result, Summit Hotel OP, LP estimated a proposed
maximum offering price per OP unit of $15.00 for purposes of the fee table of the S-4
Registration Statement. The price range for the Company’s common stock in the initial
public offering will be determined by the Company and the underwriters based upon market
conditions and other factors at the time the offering marketing process begins and may, but
will not necessarily, correspond to the $15.00 assumed value used to establish the merger
consideration. Once determined, the Company will include on the prospectus cover page the
price range for the Company’s common stock in the initial public offering.

Summary, page 1

    7.

    Please move the “Summary Risk Factors” section to immediately follow the “Our Competitive
Strengths” section.

Ms. Kristina Aberg

Ms. Sonia Gupta Barros

September 22, 2010

Page 5

    RESPONSE: The Company has moved the “Summary Risk Factors” section to page 3 in
response to the Staff’s comment.

    8.

    We refer to your statement in the first paragraph on page 3 that your executive officers
collectively have over 60 years of experience in the hotel business. Please do not aggregate
the experience of your management.

    RESPONSE: The Company has revised the disclosure on pages 2 and 72 in response to
the Staff’s comment.

    9.

    Please revise to eliminate unnecessary repetition from the summary. For example, much of the
information you disclose in the “Overview” and “Our Competitive Strengths” sections in the
summary is repeated in the “Our Business and Properties” section beginning on page 75.

    RESPONSE: The Company has revised the disclosure on pages 1-6, 11 and elsewhere in response
to the Staff’s comment.

Our Competitive Strengths, page 2

    10.

    Please explain what you mean by “stabilized cash flows.”

    RESPONSE: The Company has revised the disclosure throughout Amendment No. 1 in
response to the Staff’s comment.

    11.

    We note your reference to the term RevPAR penetration index and your disclosure of your
weighted-average RevPAR penetration index. Please move all your disclosure regarding this
calculation to a section of the prospectus where you have explained in detail how the index is
determined. For example, we refer to your discussion on pages 56 and 57.

    RESPONSE: The Company has revised the disclosure on page 76 and elsewhere in
response to the Staff’s comment.

Our Industry and Market Opportunity, page 5

    12.

    We note your reference in this section to a “below table” regarding RevPAR growth. We are
unable to locate such a table in the summary section. Please remove the reference or explain.

Ms. Kristina Aberg

Ms. Sonia Gupta Barros

September 22, 2010

Page 6

    RESPONSE: The Company has revised the disclosure on page 5 in response to the
Staff’s comment.

Summary Risk Factors, page 6

    13.

    Please include a statement, here and in the Distribution Policy section beginning on page 12,
that you may be required to borrow funds or sell assets to pay distributions or that you may
issue stock to satisfy your distribution requirements. In addition, please revise your
disclosure to state that you may use proceeds from this or other offerings to pay
distributions.

    RESPONSE: The Company has revised the disclosure on pages 3 and 11 and 46 in
response to the Staff’s comment.

Our Formation Transactions, page 7

    14.

    We note that in connection with the reorganization, your operating partnership will issue
9,993,992 OP units to your predecessor’s members. We refer to your disclosure on page 14 that
your operating partnership will have 10,100,000 units outstanding after the merger. Please
clarify, if true that the 1,517,879 OP units to be issued to Mr. Boekelheide and his
affiliates, and the 4,105 OP units to be issued to Mr. Aniszewski are included in the
9,993,992 OP units being issued to your predecessor’s members. Also clarify here who will
receive the remaining 106,008 OP units that will be issued.

    RESPONSE: The Company has added disclosure on page 6 in response to the Staff’s
comment.

Risk Factors

    15.

    Several of your risk factors include lengthy bullet point lists. Please review your risk
factors to ensure that each risk factor presents only one risk. We note the following risk
factors by way of example only.

    •

    We may be unable to complete acquisitions that would grow our business, and even if
they are completed, we may fail to successfully integrate and operate such acquired
hotels, page 20;

    •

    Joint venture investments could be adversely affected by a lack of sole
decision-making authority and our reliance on the financial condition of our joint
venture partners, page 25.

Ms. Kristina Aberg

Ms. Sonia Gupta Barros

September 22, 2010

Page 7

    •

    Our operating results and ability to make distributions may be adversely affected by
the markets in which we operate and risks inherent to the ownership of hotels, page 26;
and

    RESPONSE: The Company has revised the disclosure on pages 18-21, 23-26 and 29 in
response to the Staff’s comment.

Use of Proceeds, page 44

    16.

    Please tell us if any of indebtedness to be discharged with the proceeds from the offering
was incurred within the last year. If so, please provide the disclosure required by
Instruction 4 to Item 504 of Regulation S-K.

    RESPONSE: The Company has added disclosure on pages 41 in response to the Staff’s
comment.

    17.

    Please also provide all the disclosure required by Instructions 5 and 6 to Item 504 of
Regulation S-K regarding proceeds from the offering to be used for acquisitions.

    RESPONSE: The Company discloses on page 41 general categories for which net
proceeds remaining after repayment of identified indebtedness and planned capital
improvements to its hotels may be used. The Company advises the Staff that the Company does
not currently have any specific probable acquisitions to disclose pursuant to Instruction 5
or 6 of Item 504 of Regulation S-K.

Distribution Policy, page 48

    18.

    Please revise your filing to remove any projections related to your initial dividend
distribution, including the table on page 50. Due to the lack of in-place leases in a typical
hotel, revenues are too difficult to predict, and as such, it is not appropriate to project an
initial dividend distribution.

    RESPONSE: The Company respectfully requests that the Staff reconsider this comment
because the Company believes that the initial dividend distribution rate is one of the most
important pieces of information available to prospective investors in REIT IPOs. The
Company’s predecessor, Summit Hotel Properties, LLC, has many years’ experience owning and
operating the hotel portfolio that will be owned by the Company upon completion of the
formation transactions. As a result, the Company believes that the pro forma financial
results for these hotel properties for the 12 months ended June 30, 2010 form an appropriate
measure of estimating the income and cash flow that will be

Ms.

September 8, 2010
 Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. 2701 South Minnesota Avenue, Suite 6 Sioux Falls, SD 57105
Re: Summit Hotel Properties, Inc.
Registration Statement on Form S-11 Filed August 9, 2010
  File No. 333-168686

Dear Mr. Hansen:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

 1. Please provide us with copies of any study or  report that you cite or on which you rely.
Clearly mark the materials to identify the por tions that support your disclosure.  Please
confirm that any other industry reports or st udies on which you rely we re not prepared for
you and that you did not compensate the party that prepared these reports or studies.
Alternatively, please file the expe rt’s consent as an exhibit to the registration statement.
 2. Please provide us with copies  of all graphics, maps, photogr aphs, and related captions or
other artwork, including logos that y ou intend to use in the prospectus.

3. We note your use of the following factual a ssertions throughout the prospectus.  The
basis for such factual assertions and for your management’s beliefs should be clear from
the text of the prospectus or supporting doc umentation should be provided to us. Please
revise your disclosure to address our concerns, or advi se us as necessary. In providing

Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. September 8, 2010 Page 2

support, clearly mark the location of the in formation you believe is supportive of the
statement referenced.  By way of example only, we note the following factual assertions:

• “We are a … leading hotel owner ….”

• “The total number of hotels in the upscal e and midscale without food and beverage hotel
segments … is more than six times larger th an the total number of hotels in the luxury
and upper upscale segments….  We also belie ve that … we will be the only publicly
traded REIT focused solely on these segments on a national basis.”

• “Our hotels are located in markets with mu ltiple demand generators in which we have
extensive experience and that have historically offered st rong risk adjust ed returns.”

• “Our initial portfolio is co mposed of 46 seasoned hotels wi th established track records
and strong positions within their markets….”

• “… our hotels’ competitive advantag es in their respective markets….”

• “Over the last twenty years, our market segments have demonstrated the strongest
compounded growth in demand of all segm ents of the lodging industry….”
 4. We note that you have not included any disc losure in response to Item 402(s) of
Regulation S-K.  Please advise us of the basis for your conclusion that disclosure is not
necessary and describe the process yo u undertook to reach that conclusion.

5. Please tell us if any portion of the purchase pr ice will represent a gain or a loss related to
the settlement of a pre-exis ting relationship, which should be accounted for separately
from the business combination. Refer to  ASC 805-10-25-20 through 25-21 and ASC 805-
10-55-20 through 55-23.
Prospectus Cover Page

 6. We note that you have omitted the price range on the cover page and throughout the
prospectus of this registration statement but have included a price ra nge for this initial
public offering in the Form S-4 for Su mmit Hotel OP, LP, file number 333-168685.
Please revise the cover page and prospectus to provide the same price range as that
provided in the Form S-4 or tell us why you have omitted it here.
   Summary, page 1

 7. Please move the “Summary Risk Factors” section to immediately follow the “Our
Competitive Strengths” section.

Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. September 8, 2010 Page 3

8. We refer to your statement in the first para graph on page 3 that your executive officers
collectively have over 60 year s of experience in the hotel  business.  Please do not
aggregate the experience of your management.
 9. Please revise to eliminate unnecessary repeti tion from the summary.  For example, much
of the information you disclose in the “O verview” and “Our Competitive Strengths”
sections in the summary is repeated in the “Our Business and Properties” section
beginning on page 75.
Our Competitive Strengths, page 2

 10. Please explain what you mean by “stabilized cash flows.”
 11. We note your reference to the term RevPAR penetration index and your disclosure of
your weighted-average RevPAR penetration index.  Please move all your disclosure
regarding this calcula tion to a section of the prospectus where you have explained in
detail how the index is determined.  For ex ample, we refer to your discussion on pages 56
and 57.

Our Industry and Market Opportunity, page 5

 12. We note your reference in this section to a “below table” regarding RevPAR growth.  We
are unable to locate such a table in the summary section.  Please remove the reference or explain.
 Summary Risk Factors, page 6

 13. Please include a statement, here and in the Distribution Policy s ection beginning on page
12, that you may be required to borrow funds or sell assets to pay dist ributions or that you
may issue stock to satisfy your distribution requi rements.  In addition, please revise your
disclosure to state that you may use pro ceeds from this or other offerings to pay
distributions.
 Our Formation Transactions, page 7

 14. We note that in connection with the reorga nization, your operating pa rtnership will issue
9,993,992 OP units to your predecessor’s members.   We refer to your disclosure on page
14 that your operating partnership will have 10,100,000 units outstanding after the
merger.  Please clarify, if true, that the 1,517,879 OP units to be issued to Mr.
Boekelheide and his affiliates, and the 4,105 OP units to be issued to Mr. Aniszewski are
included in the 9,993,992 OP units being issued to your predecessor’s members.  Also
clarify here who will receive the remaini ng 106,008 OP units that will be issued.

Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. September 8, 2010 Page 4

Risk Factors

 15. Several of your risk factors include lengthy bullet point lists.  Pl ease review your risk
factors to ensure that each risk factor pr esents only one risk. We note the following risk
factors by way of example only.

• We may be unable to complete  acquisitions that would grow  our business, and even if
they are completed, we may fail to successf ully integrate and ope rate such acquired
hotels, page 20;
• Joint venture investments could be adversely affected by a lack of sole decision-making
authority and our reliance on the financial c ondition of our joint venture partners, page
25.
• Our operating results and ability to make di stributions may be adversely affected by the
markets in which we operate and risks inherent  to the ownership of hotels, page 26; and
 Use of Proceeds, page 44

 16. Please tell us if any of indebtedness to be discharged with the proceeds from the offering
was incurred within the last year.  If s o, please provide the disclosure required by
Instruction 4 to Item 504 of Regulation S-K.

17. Please also provide all the disclosure require d by Instructions 5 and 6 to Item 504 of
Regulation S-K regarding proceeds from the offering to be used for acquisitions.
 Distribution Policy, page 48

 18. Please revise your filing to remove any pr ojections related to your initial dividend
distribution, including the table on page 50.  Due to the lack of in-place leases in a typical
hotel, revenues are too difficult to  predict, and as such, it is not appropriate to project an
initial dividend distribution.
 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page 54

 19. We note that your predecessor may pay accrued and unpaid priority returns on Class A
and Class A-1 membership interests through the business day immedi ately prior to the
closing date of the related merger with th e predecessor’s available cash flow.  Please
discuss the impact this may have on your predecessor’s liquidity.

Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. September 8, 2010 Page 5

Key Operating Metrics, page 56

 20. We refer to your discussion he re and on page 80 of the me thodology used to calculate
RevPAR penetration index and note that it is subject to the minimum criteria established
by Smith Travel Research.  It is unclear from  your disclosure, howev er, what additional
criteria you use to calculate your RevPAR  penetration index.  Please revise your
disclosure to clarify if  you use additional criteria.   In addition, please tell  us if this metric
is calculated by you or by Smith Travel Research on your behalf.
 Liquidity and Capital Resources, page 65

 21. Please revise your discussion of liquidity to disclose the amount of debt for which you
have not yet received lender consents for th e merger.  Please include a discussion of what
you intend to do if any of these lenders ulti mately will not provide consents.  To the
extent you would have to repay outstanding debt , please reflect this  in your pro forma
financial statements.
 Contractual Obligations, page 68

22. In addition to the contractual obligations ta ble on a pro forma basis, please revise to
include a contractual obligations table on a historical basis.
 Our Portfolio, page 83

 23. Please tell us how you will account for the sale  of the eight parcels of vacant land.
 Our Hotel Operating Agreements, page 95

 24. Please provide a summary of the key terms of your franchise agreements and your
agreements with your hotel manager.  Your de scription should address material fees, the
term of the agreements, material termination provisions such as those based upon performance or financial metrics and other material terms.
 Assets Held for Sale, page F-20

 25. Please revise your accounting policy for assets held  for sale to value th em at the lesser of
historical cost or fair value less costs to sell.  Refer to ASC 360-35-38 to 35-40.
Additionally, you note that you have committe d to sell six parcels of land, but the
disclosure on page 83 indicates there are ei ght parcels of land which you have committed
to sell.  Please clarify these references are to  the same assets, and reconcile the difference.

Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. September 8, 2010 Page 6

Item 33. Recent Sales of Unregistered Securities, page II-1

 26. We note that you issued and sold shares in  reliance upon exemptions  from registration
pursuant to Section 4(2) of the Securities Act and Regulation D.  Beginning March 16, 2009,
we required all filers to submit their Forms D electronically on EDGAR.  See Guidance on
Form D Filing Process located at http://www. sec.gov/divisions/corpfin/formdfiling.htm.
Please promptly file copies of any required Form D.
 Item 36.  Financial Statements and Exhibits, page II-2

 27. Please file your remaining exhibits as soon as possible in order to allow us sufficient time
to review those documents.  If you are not pr epared to file your legal and tax opinions
with your next amendment, please provide  draft opinions for us to review.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

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

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Mr. Daniel P. Hansen President and Chief Executive Officer Summit Hotel Properties, Inc. September 8, 2010 Page 7

 You may contact Eric McPhee, Staff Account ant, at (202) 551-3693 or Daniel Gordon,
Branch Chief, at (202) 551-3486 if you have que stions regarding comments on the financial
statements and related matters.  Please contac t Kristina Aberg, Attorney-Advisor, at (202) 551-
3404 or me at (202) 551-3655 with any other questions.
Sincerely,

Sonia Gupta Barros Special Counsel
 cc: David C. Wright, Esq.  Edward W. Elmore, Esq.  Hunton & Williams LLP