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United States securities and exchange commission logo
October 13, 2023
Jihong He
Chief Financial Officer
H World Group Ltd.
No. 1299 Fenghua Road
Jiading District, Shanghai 201803
People s Republic of China
Re: H World Group Ltd.
Form 20-F for the
Fiscal Year Ended December 31, 2022
Response dated
August 28, 2023
File No. 001-34656
Dear Jihong He:
We have reviewed your August 28, 2023 response to our comment
letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our August 4,
2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 45
1. We note your response
to prior comment 2 that three directors of the Company and/or its
consolidated foreign
operating entities advised that they are CCP members and they act as
the secretary in
different primary-level party organizations of Huazhu group. Please
clarify for us the
directors to which you refer and specifically describe their roles and
responsibilities within
the different primary-level party organizations of the Huazhu
group. In addition,
please explain to us in detail how you considered their roles and
responsibilities in
your determination that they are not CCP officials.
Jihong He
H World Group Ltd.
October 13, 2023
Page 2
Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at
202-551-3377 with
any questions.
FirstName LastNameJihong He Sincerely,
Comapany NameH World Group Ltd.
Division of Corporation
Finance
October 13, 2023 Page 2 Disclosure Review
Program
FirstName LastName