May 15, 2019
Mr. Peter McPhun
Mr. Wilson K. Lee
Office of Real Estate and Commodities
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, NE, Mail Stop 3561
Washington, DC 20549
| RE: | Red Lion Hotels Corporation |
Form10-K for the fiscal year ended December 31, 2018
Filed March 8, 2019
Form8-K
Filed March 8, 2019
FileNo. 001-13957
Dear Mr. McPhun and Mr. Lee:
We are responding to your comment letter, dated May 6, 2019, relating to the Form10-K for fiscal year ended December 31, 2018 and the Form8-K, both filed by Red Lion Hotels Corporation (the “Company”) on March 8, 2019.
For ease of reference we have repeated your comment in bold text that precedes the response.
Form8-K filed on March 8, 2019
Exhibit 99.1
2019 Expectations, page 3
| 1. | We note you disclosed an expected 2019 range for Adjusted EBITDA from continuing operations. In future filings, please provide the reconciliations required by Item 10(e)(1)(i) of RegulationS-K. To the extent you are relying on the “unreasonable efforts” exception in Item 10(e)(1)(i)(B), please revise future filings to disclose this fact and identify any information that is unavailable and its probable significance. Reference is made to Question 102.10 of the Division’s Compliance and Disclosure Interpretations forNon-GAAP Financial Measures. |
The Company acknowledges the Staff’s comment. In future filings the Company will provide reconciliations to the most directly comparable GAAP financial measures fornon-GAAP measures used to provide guidance for subsequent periods.
If you need any additional information, or if we can be of any further assistance, please call me at(509) 777-6393 or reach me by email atJulie.Shiflett@rlhco.com.
Very truly yours,
/s/ Julie Shiflett
Julie Shiflett
Executive Vice President and Chief Financial Officer
Red Lion Hotels Corporation