Mail Stop 3233

                                                                   June 19,
2018

Via E-mail
Lawrence M. Cuculic
Senior Vice President, General Counsel and
Corporate Secretary
Best Western International, Inc.
6201 N. 24th Parkway
Phoenix, AZ 85016

       Re:     Best Western International, Inc.
               Amendment No. 1 to
               Draft Registration Statement on Form S-1
               Submitted May 29, 2018
               CIK No. 0001733381

Dear Mr. Cuculic:

      We have reviewed your amended draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

General

1.     Please tell us whether you have had pre-filing communications relating
to the proposed
       offering. If so, please provide your analysis regarding how those
communications are
       permissible in light of the pre-filing communications requirements of
the Securities Act
       of 1933.
 Lawrence M. Cuculic
Best Western International Inc.
June 19, 2018
Page 2

2.      It appears that the offering, as structured with respect to
contingently-approved applicants
        constructing new properties, fails to comply with Securities Act Rule
415(a)(2). In this
        regard, your offering is structured to continue beyond two years from
the initial effective
        date. Please revise or tell us how you believe the offering complies
with Rule 415.

3.      We note your response to comment 6, the transfer restrictions
applicable to the Common
        Stock, and your representation that the seven series of Common Stock
will convert into a
        single series upon consummation of an initial public offering. Please
confirm that you do
        not plan to register the Common Stock under Exchange Act Section 12
while the
        different series are outstanding. Please also tell us what
consideration you have given to
        providing expanded beneficial ownership disclosure on a series basis,
to provide
        transparency as to significant holdings with respect to each series.

       You may contact Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or
Robert Telewicz,
Branch Chief, at (202) 551-3438 if you have questions regarding comments on the
financial
statements and related matters. Please contact Joshua Lobert, Staff Attorney,
at (202) 551-7150
or me at (202) 551-3215 with any other questions.


                                                             Sincerely,

                                                             /s/ Kim McManus

                                                             Kim McManus
                                                             Senior Attorney
                                                             Office of Real
Estate and
                                                             Commodities

cc:     Edward J. Schneidman, Esq.
        Kirkland & Ellis LLP