May 6, 2019

Julie Shiflett
Executive Vice President and Chief Financial Officer
Red Lion Hotels Corporation
1550 Market Street #350
Denver, Colorado 80202

       Re: Red Lion Hotels Corporation
           Form 10-K for the fiscal year ended December 31, 2018
           Filed March 8, 2019
           Form 8-K
           Filed March 8, 2019
           File No. 001-13957

Dear Ms. Shiflett:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 8-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 Regulation S-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 for
       Non-GAAP Financial Measures.

       In closing, we remind you that the company and its management are
responsible for the
 Julie Shiflett
Red Lion Hotels Corporation
May 6, 2019
Page 2

accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Peter McPhun, Staff Accountant, at 202-551-3581 or
Wilson K. Lee,
Senior Staff Accountant, at 202-551-3468 with any questions.



                                                          Sincerely,
FirstName LastNameJulie Shiflett
                                                          Division of
Corporation Finance
Comapany NameRed Lion Hotels Corporation
                                                          Office of Real Estate
and
May 6, 2019 Page 2                                        Commodities
FirstName LastName