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                            September 17, 2021

       Haijun Wang
       Chairman and Chief Executive Officer
       Atour Lifestyle Holdings Limited
       18th floor, Wuzhong Building
       618 Wuzhong Road, Minhang District
       Shanghai, People's Republic of China

                                                        Re: Atour Lifestyle
Holdings Limited
                                                            Amendment No. 3 to
Registration Statement on Form F-1
                                                            Filed August 31,
2021
                                                            File No. 333-256881

       Dear Mr. Wang:

             We have reviewed your amended registration statement 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 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 registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
August 19, 2021 letter.

       Amendment No. 3 to Registration Statement on Form F-1 filed August 31,
2021

       Cover Page

   1.                                                   We note your response
to comment 1. Please revise your prospectus summary to address
                                                        all the risks
highlighted on the prospectus cover page and clarify that these risks could
                                                        result in a material
change in your operations and/or the value of your Class A Ordinary
                                                        Shares/ADSs or could
significantly limit or completely hinder your ability to offer or
                                                        continue to offer
securities to investors and cause the value of such securities to
                                                        significantly decline
or be worthless. Similarly, your disclosure in the prospectus
                                                        summary should also
address how recent statements and regulatory actions by China   s
                                                        government, such as
those related to data security or anti-monopoly concerns, has or may
 Haijun Wang
FirstName  LastNameHaijun   Wang
Atour Lifestyle Holdings Limited
Comapany 17,
September  NameAtour
               2021    Lifestyle Holdings Limited
September
Page 2     17, 2021 Page 2
FirstName LastName
         impact the company   s ability to conduct its business, accept foreign
investments, or list on
         an U.S. or other foreign exchange.
Prospectus Summary, page 1

2.       We note your response to comment 2. Please revise your summary of risk
factors on page
         4 to specifically discuss the risk that the Chinese government may
intervene or influence
         your operations at any time, or may exert more control over offerings
conducted overseas
         and/or foreign investment in China-based issuers, which could result
in a material change
         in your operations and/or the value of your Class A Ordinary
Shares/ADSs. Also revise
         your summary of risk factors to acknowledge any risks that any actions
by the Chinese
         government to exert more oversight and control over offerings that are
conducted overseas
         and/or foreign investment in China-based issuers could significantly
limit or completely
         hinder your ability to offer or continue to offer securities to
investors and cause the value
         of such securities to significantly decline or be worthless.
3.       We note your response to comment 3 and your risk factor disclosure
that    there are no
         PRC laws and regulations in force explicitly requiring that we obtain
any permission from
         PRC authorities to issue securities to foreign investors.    Please
provide this disclosure in
         the prospectus summary. With respect to approval of your operations,
clearly state in the
         prospectus summary whether you or your subsidiaries are covered by
permissions
         requirements from the CSRC, CAC or any other entity that is required
to approve your
         operations and state affirmatively whether you have received all
requisite permissions and
         whether any permissions have been denied.
Holding Company Structure, page 6

4.       We note your revisions in response to comment 4. Please address the
following with
         respect to your revised disclosure:
             In your disclosure you state that appropriation to the general
reserve fund is not
             required if the fund has reached 50% of the registered capital of
your subsidiaries.
             Please revise your disclosure to discuss whether your subsidiaries
are still required to
             contribute to the general reserve fund, and whether these
contributions are expected
             end in the near term.
             In your revised disclosure you state that your contributions to
the enterprise
             expansion fund and the staff and bonus welfare fund can be made at
your
             subsidiaries    discretion. Please disclose your subsidiaries
historic contributions to
             each fund for each financial statement period presented.
             Finally, we note your disclosure that distributions can only be
made out of retained
             earnings as defined by Accounting Standards for Business
Enterprise as promulgated
             by the Ministry of Finance. Please disclose the retained earnings
(deficit) for your
             subsidiaries as determined by Accounting Standards for Business
Enterprise as
             promulgated by the Ministry of Finance for each period presented
in the financial
             statements.
 Haijun Wang
Atour Lifestyle Holdings Limited
September 17, 2021
Page 3
Risk Factors
Uncertainties with respect to the PRC legal system, including uncertainties
regarding the
enforcement of laws..., page 47

5.     We note your response to comment 5 and your disclosure in the last
paragraph beginning
       on page 47 that government intervention or influence could adversely
affect your
       business, financial condition and results of operations. Please expand
your disclosure to
       state that any such intervention or influence could also result in a
material change in the
       value of your ADSs. The statement on page 48 that the value of your
securities could
       become worthless appears limited to actions by the government to exert
oversight and
       control over securities offerings and capital markets activities only.
       You may contact Frank Knapp at 202-551-3805 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ronald (Ron) E. Alper at 202-551-3329 or James Lopez at 202-551-3536
with any other
questions.



                                                             Sincerely,
FirstName LastNameHaijun Wang
                                                             Division of
Corporation Finance
Comapany NameAtour Lifestyle Holdings Limited
                                                             Office of Real
Estate & Construction
September 17, 2021 Page 3
cc:       Li He, Esq.
FirstName LastName