November 26, 2019 Thomas L. McKeirnan Executive Vice President and General Counsel Red Lion Hotels Corporation 201 W. North River Drive, Suite 100 Spokane, WA 99201 Re: Red Lion Hotels Corporation Registration Statement on Form S-3 File No. 333-234802 Filed November 20, 2019 Dear Mr. McKeirnan: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jonathan Burr at 202-551-5833 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction