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                             September 22, 2022

       Paul Abbott
       Chief Executive Officer and Director
       Global Business Travel Group, Inc.
       666 3rd Avenue, 4th Floor
       New York, NY 10017

                                                        Re: Global Business
Travel Group, Inc.
                                                            Registration
Statement on Form S-4
                                                            Filed September 9,
2022
                                                            File No. 333-267339

       Dear Mr. Abbott:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-4

       Cautionary Note Regarding Forward Looking Statements, page 2

   1.                                                   The safe harbor for
forward-looking statements provided in the Private Securities
                                                        Litigation Reform Act
by its terms does not apply to statements made in connection with a
                                                        tender offer. Please
revise the disclosure in this section accordingly.
       The Offer and Consent Solicitation
       Background and Purpose of the Offer and Consent Solicitation, page 67

   2.                                                   Please expand your
disclosure regarding the background and purpose of the exchange
                                                        offer and consent
solicitation. In this regard, we note that your Class A common stock
                                                        has been trading at or
below $8.77 per share since June 2, 2022 and had a closing share
                                                        price of $6.58 on
September 20, 2022. We further note the risk factor disclosure you
 Paul Abbott
Global Business Travel Group, Inc.
September 22, 2022
Page 2
      included in your joint proxy statement/prospectus for your business
combination on Form
      S-4 stating that outstanding warrants may expire worthless unless the
Acquiror Cayman
      Class A Ordinary Share price or Domesticated Acquiror Class A Common
Stock price, as
      applicable, is higher than the exercise price during the exercise period.
3.    We note your disclosure that one of the purposes of the offer and consent
solicitation is to
      attempt to reduce the potential dilutive impact of the warrants. Please
clarify whether you
      considered the dilutive impact of the exchange offer on your current
stockholders. In this
      regard, we note your risk factor disclosure on page 56 stating that your
warrants may be
      exchanged for shares of Class A Common Stock pursuant to the offer, which
will increase
      the number of shares eligible for future resale in the public market and
result in dilution to
      your stockholders.
4.    Clarify to disclose that the private warrant holders will participate in
the exchange offer
      and that pursuant to the APSG IPO, the Company sold an aggregate of
12,224,134 Private
      Placement Warrants to the Sponsor at a purchase price of $1.50 per
Private Placement
      Warrant.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       For comments from the Office of Mergers & Acquisitions, you may contact
Christina
Chalk, Senior Special Counsel, at 202-551-3263. You may contact Irene
Barberena-Meissner,
Staff Attorney, at 202-551-6548 or Loan Lauren Nguyen, Legal Branch Chief, at
202-551-3642
with any other questions.



                                                             Sincerely,
FirstName LastNamePaul Abbott
                                                             Division of
Corporation Finance
Comapany NameGlobal Business Travel Group, Inc.
                                                             Office of Energy &
Transportation
September 22, 2022 Page 2
cc:       Gregory A. Fernicola, Esq.
FirstName LastName