View:
United States securities and exchange commission logo
June 16, 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
Form 6-K filed May
29, 2020
File No. 001-33853
Dear Ms. Wang:
We have reviewed your filings 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 these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
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. Please revise your
discussion to provide an analysis of the specific factors that impacted
revenues and expenses.
For example, you discuss that revenues from your accommodation
reservation business
increased due to your brands' extensive reach and provision of
diversified
accommodation choices to prospective customers, and revenues from your
transportation
ticketing business increased due to an increase in demands for international
air tickets and ground
transportation tickets, but you do not provide an analysis as to why
these factors caused
revenues to increase. Refer to Section III.B.4 of SEC Release No. 33-
Cindy Xiaofan Wang
Trip.com Group Ltd
June 16, 2020
Page 2
8350 for guidance.
Please also provide a discussion of the extent to which changes in
revenues are
attributable to changes in prices or volume. Refer to Item 5.A of Form
20-F.
General
2. We note your disclosure in your Form 6-K filed on May 29, 2020,
discussing the expected
net revenue decrease in future periods due to the continued negative
impact of COVID-19.
In future filings, please discuss the impact of COVID-19 on other
income statement
financial measures, such as cost of revenue or net income, to provide
additional context
for investors. In this regard, a single financial measure, such as
revenue, may be
considered an incomplete picture of your results of operation or
financial condition.
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.
You may contact Patrick Kuhn at (202) 551-3308 or Lyn Shenk at (202)
551-3380 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at (202) 551-3342 or Jennifer Lopez-Molina at (202)
551-3792 with any
other questions.
FirstName LastNameCindy Xiaofan Wang Sincerely,
Comapany NameTrip.com Group Ltd
Division of
Corporation Finance
June 16, 2020 Page 2 Office of Trade &
Services
FirstName LastName