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                              August 19, 2021

       Haijun Wang
       Chairman and Chief Executive Officer
       Atour Lifestyle Holdings Limited
       18th floor, Wuzhong Building
       618 Wuzhong Road, Minhang District
       Shanghai, People's Republic of China

                                                        Re: Atour Lifestyle
Holdings Limited
                                                            Amendment No. 2 to
Registration Statement on Form F-1
                                                            Filed July 12, 2021
                                                            File No. 333-256881

       Dear Mr. Wang:

             We have reviewed your amended registration statement 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 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.

       Amended Form F-1

       Cover Page

   1.                                                   Provide prominent
disclosure about the legal and operational risks associated with being
                                                        based in or having the
majority of the company   s operations in China. Your disclosure
                                                        should make clear
whether these risks could result in a material change in your operations
                                                        and/or the value of
your Class A Ordinary Shares/ADSs or could significantly limit or
                                                        completely hinder your
ability to offer or continue to offer securities to investors and
                                                        cause the value of such
securities to significantly decline or be worthless. Your disclosure
                                                        should address how
recent statements and regulatory actions by China   s government, such
                                                        as those related to
data security or anti-monopoly concerns, has or may impact the
                                                        company   s ability to
conduct its business, accept foreign investments, or list on an U.S. or
 Haijun Wang
FirstName  LastNameHaijun   Wang
Atour Lifestyle Holdings Limited
Comapany
August 19, NameAtour
           2021        Lifestyle Holdings Limited
August
Page 2 19, 2021 Page 2
FirstName LastName
         other foreign exchange. Your prospectus summary should address, but
not necessarily be
         limited to, the risks highlighted on the prospectus cover page.
2.       In your summary of risk factors, disclose the risks that being based
in and having the
         majority of the company   s operations in China poses to investors. In
particular, describe
         the significant regulatory, liquidity, and enforcement risks with
cross-references to the
         more detailed discussion of these risks in the prospectus. For
example, specifically
         discuss risks arising from the legal system in China, including risks
and uncertainties
         regarding the enforcement of laws and that rules and regulations in
China can change
         quickly with little advance notice; and the risk that the Chinese
government may intervene
         or influence your operations at any time, or may exert more control
over offerings
         conducted overseas and/or foreign investment in China-based issuers,
which could result
         in a material change in your operations and/or the value of your Class
A Ordinary
         Shares/ADSs. Acknowledge any risks that any actions by the Chinese
government to
         exert more oversight and control over offerings that are conducted
overseas and/or foreign
         investment in China-based issuers could significantly limit or
completely hinder your
         ability to offer or continue to offer securities to investors and
cause the value of such
         securities to significantly decline or be worthless.
3.       Disclose each permission that you or your subsidiaries are required to
obtain from Chinese
         authorities to operate and issue these securities to foreign
investors. State whether you or
         your subsidiaries are covered by permissions requirements from the
CSRC, CAC or any
         other entity that is required to approve your operations, and state
affirmatively whether
         you have received all requisite permissions and whether any
permissions have been
         denied.
4.       Provide a clear description of how cash is transferred through your
organization. Quantify
         any cash flows and transfers of other assets by type that have
occurred between the
         holding company, its subsidiaries, and direction of transfer. Quantify
any dividends or
         distributions that a subsidiary has made to the holding company and
which entity made
         such transfer, and their tax consequences. Similarly quantify
dividends or distributions
         made to U.S. investors, the source, and their tax consequences.
Describe any restrictions
         on foreign exchange and your ability to transfer cash between
entities, across borders, and
         to U.S. investors. Describe any restrictions and limitations on your
ability to distribute
         earnings from your businesses, including subsidiaries to the parent
company and U.S.
         investors.
Risk Factors, page 21

5.       Given the Chinese government   s significant oversight and discretion
over the conduct of
         your business, please revise to separately highlight the risk that the
Chinese government
         may intervene or influence your operations at any time, which could
result in a material
         change in your operations and/or the value of your Class A Ordinary
Shares/ADSs. Also,
         given recent statements by the Chinese government indicating an intent
to exert more
         oversight and control over offerings that are conducted overseas
and/or foreign investment
 Haijun Wang
Atour Lifestyle Holdings Limited
August 19, 2021
Page 3
      in China-based issuers, where you acknowledge the risk that any such
action could
      significantly limit or completely hinder your ability to offer or
continue to offer securities
      to investors, please clarify that these actions may not only have a
material adverse effect
      on the trading price of your ADSs but could cause the value of such
securities to
      significantly decline or be worthless.
We may be liable for improper use or appropriation of personal information
provided by our
customers, page 40

6.    We note your disclosure on pages 40     41 describing the ways in which
your business
      may be impacted by the uncertainties raised by greater oversight by the
Cybersecurity
      Administration of China over data security, particularly for companies
seeking to list on a
      foreign exchange. Please expand to explain how this oversight impacts
your offering, and
      to what extent you believe that you are compliant with the regulations or
policies that have
      been issued by the CAC to date.
Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2

7.    It appears you have made significant changes to your audited financial
statements. Please
      tell us whether these changes were subject to audit, and if so, explain
to us what
      consideration your auditor gave to dual dating their audit opinion.
       You may contact Frank Knapp at 202-551-3805 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ronald Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with
any other
questions.



                                                             Sincerely,
FirstName LastNameHaijun Wang
                                                             Division of
Corporation Finance
Comapany NameAtour Lifestyle Holdings Limited
                                                             Office of Real
Estate & Construction
August 19, 2021 Page 3
cc:       Li He, Esq.
FirstName LastName