| Re: | Home Inns & Hotels Management Inc. (the “Company”) Form 20-F for the fiscal year ended December 31, 2010 Filed April 27, 2011 File No. 001-33082 |
| 1. | In future filings, please revise your MD&A to describe the seasonality of your business and how it impacts your revenues and business operations. See Item 4.B.3 ofForm 20-F. | |
| In response to the Staff’s comment, in the MD&A of future filings the Company will describe the seasonality of its business and how revenues and business operations are impacted by seasonality. |
| 2. | In future filings, please revise to provide the occupancy rate, average daily rate and RevPAR for your leased-and-operated hotels and your franchised-and-managed hotels. In addition, in future filings, please provide the occupancy rate, average daily rate and RevPAR for mature hotels as well as those that are in the ramp up phase and clarify how you define mature hotels. | |
| In response to the Staff’s comment, in future filings the Company will provide the occupancy rate, average daily rate and RevPAR for leased-and-operated hotels, franchised-and-managed hotels, mature hotels and hotels that are in ramp up phase, as well as details regarding how the Company defines mature hotels. | ||
| 3. | We note your disclosure within this section that you view EBITDA as a key performance indicator. Given this, in future periodic filings please provide your EBITDA for the periods covered by the MD&A and reconcile this figure to net income as presented in your consolidated statements of operations. | |
| In response to the Staff’s comment, in future filings the Company will provide EBITDA for the periods covered by the MD&A and reconcile this figure to net income as presented in the Company’s consolidated statements of operations. |
| 4. | We note that your future revenue growth will depend significantly upon, among other things, your ability to maintain any future increase in your occupancy rates, average daily rates and RevPAR at existing hotels. For each of these performance indicators, in future filings, please disclose the trends in your market. | |
| In response to the Staff’s comment, in future filings the Company will describe trends in the occupancy rates, average daily rates and RevPAR of the economy hotel market in China to the extent such market information is known to the Company. |
| 5. | In future periodic filings, please include additional analysis of your capitalized expenditures by breaking down total capital expenditures between new development, redevelopment/renovations and other cap-ex by year. In addition, please provide a narrative discussion for fluctuations from year to year and expectations for the future. | |
| In response to the Staff’s comment, in future filings the Company will include a breakdown of total capital expenditures into development of new hotels, redevelopment/renovations and other capital expenditures by year. In addition, the Company will provide a narrative discussion for fluctuations from year to year and expectations for the future. |
| • | 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. |
| Very truly yours, | ||||
| /s/ Huiping Yan | ||||
| Huiping Yan Chief Financial Officer | ||||
| cc: | David Jian Sun, Director and Chief Executive Officer, Home Inns & Hotels Management Inc. Z. Julie Gao, Esq., Skadden, Arps, Slate, Meagher & Flom, Hong Kong |
