SecProbe.io

Mail Stop 4561

      July 17, 2007

VIA U.S. MAIL AND FAX (8610) 82618163

Onward Choi
Acting Chief Financial Officer
SP Tower D
26th Floor
Tsinghua Science Park Building 8
No.1 Zhongguancun East Road
Haidian District Beijing 100084
People's Republic of China

Re: NetEase.com, Inc.
Form 20-F for Fiscal Year Ended
  December 31, 2006
  Filed June 26, 2007
  File No. 000-30666

Dear Mr. Choi:

We have reviewed your filing and have the following comments.  In our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.  After reviewing this inform ation, we may raise additional comments.

 Please understand that the purpose of our re view 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.

Onward Choi
NetEase.com, Inc.
July 17, 2007 Page 2
Form 20-F for the year ended December 31, 2006

Item 5. Operating and Financial Review and Prospects

F. Tabular Disclosure of C ontractual Obligations, page 78

1. It does not appear that y ou have included your long-term payables and your zero
coupon convertible subordinated notes in your tabular disclosure of contractual obligations.  Please explain to us why you have omitted these obligations.  Please refer to the instruction to  Item 5F of Form 20-F.

Financial Statements

Consolidated Statements of Operations and Comprehensive Income, page F-5

2. Please tell us why you have presented busin ess taxes as a reduction to revenues to
determine net revenues.  Please cite au thoritative literature relied upon to justify
current presentation.

Notes to the Consolidated Financial Statements

Note 5. Prepayments and Other Current Assets, page F-21

3. We note you have employee advances and st aff loan receivables outstanding as of
December 31, 2006.  Please tell us from whom these amounts are due and whether any of these amounts are due from executive officers.  If any amounts are due from executive officers, please tell us how you have complied with section
402 of the Sarbanes-Oxley Act.

Note 15. Stock-based Compensation, page F-31

4. It does not appear that you have provided all the required disclosures in accordance with SFAS 123(R).  Please explain to us how you have complied with the disclosure requirements of paragr aphs 64 and A240-A 241 of SFAS 123(R).

Exhibits 12.1 and 12.2

5. We note your certifications do not comply w ith the content of the certifications
required under Exchange Act Rules 13a- 14(a) and 15d-14(a).  Specifically, we
note you have included the titl e of the certifying individu al at the beginning of the
certification and you have replaced the wo rd “report” with “annual report” in
paragraph 2.  Please revise your certificati ons in future filings to comply with the
Exchange Act Rules.
*    *    *    *

Onward Choi
NetEase.com, Inc.
July 17, 2007 Page 3
Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please f ile your response letter on EDGAR.  Please
understand that we may have additional comm ents after reviewing your response 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 info rmed decision.  Since the company and its
management are in possession of all facts re lating 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

You may contact Jennifer Monick, Sta ff Accountant at (202) 551-3295, or the
undersigned at (202) 551-3629 if you have questions.

        S i n c e r e l y ,

Kevin Woody
Branch Chief