September 21, 2005

Via U.S. Mail

Isadore Sharp
Chief Executive Officer
1165 Leslie Street
Toronto, Ontario
Canada, M3C 2K8

RE:		Four Seasons Hotels Inc.
      40-F for the fiscal year ended December 31, 2004
		File No. 001-14572

Dear Mr. Sharp:

      We have limited our review of your Form 40-F to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 40-F.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



General -

We note the disclosure on page 13 of Exhibit 1 to your 40-F for
the
fiscal year ended December 31, 2004, your Annual Information Form,
regarding the Four Seasons Hotel  currently under construction and
development in Damascus, Syria.  In light of the fact that Syria
has
been identified by the U.S. State Department as a state sponsor of
terrorism, and is subject to economic sanctions administered by
the
U.S. Treasury Department`s Office of Foreign Assets Control,
please
advise us of the stage of development of the Damascus hotel; your
past and present contacts with Syria; the materiality to you of
your
past, current and proposed contacts with Syria; and your view as
to
whether those contacts constitute a material investment risk for
your
security holders.  In preparing your response please consider that
evaluations of materiality should not be based solely on
quantitative
factors, but should include consideration of all factors that a
reasonable investor would deem important in making an investment
decision, including the potential impact of corporate activities
upon
a company`s reputation and share value.   In this regard, we note
that legislation requiring divestment from, or reporting of
interests
in, companies that do business with U.S.-designated state sponsors
of
terrorism has been adopted by Arizona and Louisiana.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.


      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk


cc: 	Karen Garnett
		Assistant Director
		Division of Corporation Finance