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United States securities and exchange commission logo
July 9, 2020
Cindy Xiaofan Wang
Chief Financial Officer and Executive Vice President
Trip.com Group Ltd
968 Jin Zhong Road
Shanghai 200335
People s Republic of China
Re: Trip.com Group Ltd
Form 20-F for
Fiscal Year Ended December 31, 2019
Filed April 9, 2020
File No. 001-33853
Response Dated June
29, 2020
Dear Ms. Wang:
We have reviewed your June 29, 2020 response to our comment
letter and have the
following comment. In our comment, we 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. Unless we note otherwise, our references to prior comments are
to comments in our
June 16, 2020 letter.
Form 20-F for Fiscal Year Ended December 31, 2019
Operating and Financial Review and Prospects
Results of Operations
2019 Compared to 2018, page 58
1. Refer to prior comment
1. We note your response that the factors referenced in the
2019 20-F when
discussing the trends, including the accommodation reservation revenue
increase and the
transportation ticketing revenue increase, were part of the Company s
efforts to address
prior comments on the 2018 Form 20-F. However, you have not provide
and analysis of those
factors nor have you quantify those factors as required by Section
III.B.4 of SEC Release
No. 33-8350. Please revise your discussion accordingly.
Cindy Xiaofan Wang
Trip.com Group Ltd
July 9, 2020
Page 2
You may contact Patrick Kuhn at (202) 551-3308 or Lyn Shenk at (202)
551-3380 if you
have any questions.
FirstName LastNameCindy Xiaofan Wang Sincerely,
Comapany NameTrip.com Group Ltd
Division of Corporation
Finance
July 9, 2020 Page 2 Office of Trade &
Services
FirstName LastName