-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, VXNdFvl6c52LyAF5wosM6S2sXM7D6lcMwVZ54xDVNTc0iC6+lsnCIY5DCoDVyTfx jhkJW35rYnl2mF2dmm/6RQ== 0000950103-09-002490.txt : 20091204 0000950103-09-002490.hdr.sgml : 20091204 20090930134237 ACCESSION NUMBER: 0000950103-09-002490 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20090930 FILER: COMPANY DATA: COMPANY CONFORMED NAME: INTERCONTINENTAL HOTELS GROUP PLC /NEW/ CENTRAL INDEX KEY: 0000858446 STANDARD INDUSTRIAL CLASSIFICATION: HOTELS & MOTELS [7011] IRS NUMBER: 250420260 STATE OF INCORPORATION: DE FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: BROADWATER PARK STREET 2: DENHAM CITY: BUCKINGHAMSHIRE STATE: X0 ZIP: UB9 5HJ BUSINESS PHONE: 4045513500 MAIL ADDRESS: STREET 1: BROADWATER PARK STREET 2: DENHAM CITY: BUCKINGHAMSHIRE STATE: X0 ZIP: UB9 5HJ FORMER COMPANY: FORMER CONFORMED NAME: SIX CONTINENTS PLC DATE OF NAME CHANGE: 19950531 CORRESP 1 filename1.htm
 
[IHG Letterhead]
 
September 30, 2009
 

VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Cecilia D. Blye
 

Re:
InterContinental Hotels Group PLC
Form 20-F for the Fiscal Year Ended December 31, 2008
Filed on April 7, 2009
File No. 1-10409

 
Dear Ms. Blye:
 

InterContinental Hotels Group PLC (the “Company”) is submitting this letter in connection with the letter dated September 29, 2009 submitted by Davis Polk & Wardwell LLP on the Company’s behalf in response to the written comments of the staff (the “Staff”)  of the Securities and Exchange Commission (the “Commission”) contained in your letter, dated August 20, 2009 with respect to the above referenced filing on Form 20-F.

On behalf of the Company, I acknowledge that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in its filings; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking action with respect to the filings; and (iii) 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.

We are grateful for the Staff’s assistance in this matter and hope that the Staff is satisfied with our responses to the issues raised.

Please do not hesitate to call me, Nicolette Henfrey, with comments or questions.


 
 
 
/s/ Nicolette Henfrey
 


 
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