SecProbe.io

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Mail Stop 0407

      							March 31, 2005

Via U.S. Mail and Fax (27-21-406-3753)
Mr. Steve Ward
Chief Financial Officer
Naspers Limited
40 Heerengracht
Cape Town, 8001
The Republic of South Africa

	RE:	Naspers Limited
      Form 20-F for the fiscal year ended March 31, 2004
		Filed September 30, 2004

Dear Mr. Ward:

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.  Where indicated, we think
you
should revise your documents in response to these comments.  If
you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  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 filing.
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.

Form 20-F for the fiscal year ended March 31, 2004

Printing and Distribution, page 35

1. We note that you own an entity that specializes in publication
gravure and litho-web magazines, brochures and advertising
material
printing.  We further note that you also provide distribution
services.  Tell us in detail your revenue recognition policy for
these services.  Tell us whether any of your print services also
includes distribution services and how the distribution services
impact your revenue recognition policy under SA GAAP and U.S.
GAAP.

Critical Accounting Policies

	Revenue Recognition, page 58

2. We note that you recognize mobile and telecommunications value-
added services revenues based on the full amount of fees charged
to
end-users by mobile operators.  Tell us more about the services
provided by each of your subsidiaries that provide such services,
which includes but is not limited to, M-Web (Thailand), Tencent
Holdings and Sportscn.  Also include a discussion of revenues form
Internet value-added services.  Tell us why you believe you should
present these revenues on a gross basis under U.S. GAAP.  Refer to
EITF 99-19.

3. We note that you normally recognize revenue based on statements
from mobile phone companies, but in other circumstances, you may
recognize revenue based on internal estimates.  More specifically,
you estimate the amounts based on the number of subscriptions and
the
volume of data transmitted between your network gateway and the
mobile operators` network gateways as confirmed by the operators.
Supplementally tell us the amount of revenues recognized under
this
method for each period presented.  Tell us how your estimates have
differed from the actual payments received from the mobile phone
companies and tell us the impact of such differences on your
results
of operations for each period presented.  Provide us with a
historical analysis of these differences and any adjustments made
to
revenue.

Results of Operations: 2004 Compared to 2003

	Operating Profit, page 68

4. We refer to your discussion of your accounting for hedged U.S.
dollar programming costs of M-Net and SuperSport at the spot rate
on
the date of the transaction, whereas such costs were previously
accounted for at the rate of the foreign exchange contract.  Tell
us
in detail your accounting under SA GAAP and if there are any
differences under U.S. GAAP.

Item 18. Financial Statements

2. Principal Accounting Policies

	(p) Revenue Recognition, page F-13

5. We note that you recognize advertising revenues from print
media
products upon publication over the period of the advertising
contract.  Discuss in detail your print media products and the
related advertising contracts.  Provide us more details of your
accounting policy under SA GAAP and tell us why you believe
recognition of revenue upon publication is appropriate.  Further,
tell us if your policy considers delivery of the print media
product.
If different, describe your accounting policy under U.S. GAAP.

20.  Provisions, page F-50

6. We note that you have reversed numerous provisions into income
during the years ended March 31, 2004 and 2003.  Explain your
rationale for the initial recording of each provision and your
basis
for reversing each provision.  Tell us if your accounting differs
under U.S. GAAP.  Disclose the impact of the reversal of such
provisions in your MD&A.

42. Differences Between South African Statements of GAAP and U.S.
GAAP, page F-85

7. Revise to provide the disclosures required by SFAS 107 and Item
18
of Form 20-F.

(m) Derivative Financial Instruments, page F-97

8. Provide us with more details of the nature of the differences
in
your accounting for derivative financial instruments between SA
GAAP
and U.S. GAAP.  If the only difference in the accounting is due to
the impact of embedded derivatives, please tell us why such
significant adjustments are included in your reconciliation to
U.S.
GAAP on page F-85 for derivatives.

(n) Post-retirement employee benefits, page F-98

9. Provide us with the details for the discount rates used.
Please
refer to EITF abstract Topic D-36 in your response.

*    *    *    *

      As appropriate, please amend your Forms 10-K and 10-Q and
respond to these comments within 10 business days or tell us when
you
will provide us with a response.  You may wish to provide us with
marked copies of the amendment to expedite our review.  Please
furnish a cover letter with your amendment that keys your
responses
to our comments and provides any requested supplemental
information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, 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.

      You may contact Michael Henderson, Staff Accountant, at
(202)
824-5551 or Kyle Moffatt, Accountant Branch Chief, at (202) 942-
1990
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 942-1990 with any
other questions.

							Sincerely,

							Larry Spirgel
							Assistant Director

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Mr. Steve Ward
Naspers Limited
March 31, 2005
Page 5

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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