Simpson Thacher & Bartlett
ICBCTOWER, 35THFLOOR
3GARDENROAD
HONGKONG
TELEPHONE: +852-2514-7600
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Direct Dial Number (852) 2514-7650 | E-mail Address clin@stblaw.com |
March 26, 2018
VIA EDGAR
Division of Corporation Finance
U.S. Securities & Exchange Commission
100 F Street N.E.
Mail Stop 3233
Washington, D.C. 20549
| Attention: | Ms. Kim McManus, Esq., Senior Attorney |
| Mr. Joshua Lobert, Esq., Staff Attorney |
| Mr. Isaac Esquivel, Staff Accountant |
| Ms. Kristi Marrone, Staff Accountant |
| Re: | GreenTree Hospitality Group Ltd. |
| Amendment No. 1 to Registration Statement on Form F-1 |
| Filed March 14, 2018 |
| File No. 333-223261 |
Ladies and Gentlemen:
On behalf of our client, GreenTree Hospitality Group Ltd., an exempted company incorporated under the laws of the Cayman Islands with limited liability (the “Company”), we enclose herewith for filing via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, Amendment No. 3 (“Amendment No. 3”) to the Company’s above-referenced registration statement on Form F-1 (the “Registration Statement”).
We enclose herewith ten (10) courtesy copies of Amendment No. 3, which has been marked to show changes to the Registration Statement filed with the Commission on March 14, 2018 (the “March 14 Filing”).
The Company has revised the March 14 Filing to reduce the number of Class A ordinary shares, represented by American depositary receipts, to be offered in its initial public offering, as well as make related updates to the disclosure.
The Company expects to price its initial public offering today, March 26, 2018 and, along with the underwriters, has submitted a request to the staff of the Commission pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933 to request that the effectiveness of the above-referenced registration statement (the “F-1 Registration Statement”) be accelerated to, and that the F-1 Registration Statement become effective at, at, 4:00 P.M., Eastern Daylight Time today, March 26, 2018, or as soon as practicable thereafter.
We greatly appreciate the Staff’s cooperation with the Company to achieve this offering timetable.
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If you have any question regarding the Registration Statement, please do not hesitate to contact me at +852-2514-7650 (work), +852-9198-4235 (mobile) or clin@stblaw.com (email) or Howie Farn at +852-2514-7668 (work), +852-6710-2672 (mobile) or hfarn@stblaw.com (email).
| Very truly yours, |
| /s/ Chris K.H. Lin |
| Chris K.H. Lin |
Enclosures
| cc: | Alex S. Xu, Chairman and Chief Executive Officer |
Xin Yue Jasmine Geffner, Chief Financial Officer
GreenTree Hospitality Group Ltd.
Daniel Fertig
Howie Farn
Simpson Thacher & Bartlett
Allen C. Wang
Latham & Watkins LLP
Alfred Yin
Ernst & Young Hua Ming LLP
Shirley Wong
Ernst & Young LLP
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