SecProbe.io

September 27, 2011
 Via-Email

Onward Choi Acting Chief Financial Officer NetEase.Com, Inc. 26/F, SP Tower D 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 the Fiscal Year Ended December 31, 2010
Filed June 22, 2011 File No. 0-30666

Dear Mr. Choi:
 We have reviewed your response dated September 2, 2011 and have the following
additional 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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
 Form 20-F for Fiscal Year Ended December 31, 2010

 Item 5.  Operating and Financial Review and Prospects, page 43

 B.  Liquidity and Capital Resources, page 60

1. We reviewed your response to comment six in our letter dated August 8, 2011 and
understand that you will include additional disclosures in othe r sections of the document
in future filings.  Notwithstanding, please in clude a discussion of  your funding policies
and objectives in terms of the manner in which treasury functions are controlled,
including how cash is transferred within the corporate structure, and the current
currencies in which cash and cash equivalents are held.  Refer to Item 5.B.2 of Form 20-
F.

Onward Choi
NetEase.Com, Inc. September 27, 2011 Page 2

2. We reviewed your response to comment se ven in our letter dated August 8, 2011.  We
believe that when significant amounts of cons olidated cash and short term investments
are permanently invested overseas and ar e not available to the parent company,
discussion about these items on a consolidated  basis may not be sufficient to understand a
company’s liquidity.  When evaluating and di scussing liquidity, a discussion of cash and
short term investments on a disaggregated basi s may be very relevant and necessary.  As
such, please disclose the amount of cash and time deposits held by your PRC subsidiaries
and variable interest entities, whether you intend to transfer the funds to your non-PRC
entities and whether you would need to accrue and pay with holding and other taxes if
funds were transferred to your non-PRC entities.
 Item 19.  Exhibits, page 91

3. We note your response to comment 12 in our le tter dated August 8, 2011 that “the license
agreements with Blizzard were made in th e ordinary course of the Company’s business
and, per section 4(b) of the Form 20-F instruc tions, would not be required to be filed as
exhibits.”  We further note your risk factor  disclosure on page 6 of your filing that
“Blizzard could terminate the license and jo int venture agreements with us, which in
either case could harm our operating results a nd business” and your risk  factor disclosure
on page 11 that “the operation of the online games licensed from Blizzard is dependent
on Shanghai EaseNet, which is owned by William Lei Ding, our Chief Executive Officer, director and major shareholder…The intere sts of Mr. Ding and the joint venture may
differ from ours and those of our shareholders .”  Please explain why your business is not
“substantially dependent” on thes e license agreements with B lizzard or why the contract
should not be considered one with a rela ted party.  Please see and explain why
Instructions 4(b)(i) and (ii) to Item 19 of Form 20-F do not apply.
 Consolidated Financial Statements

 Management’s Report on Internal Cont rol over Financial Reporting, page F-1

4. We reviewed your response to comment 14 in our letter dated August 8, 2011.  Please
elaborate on your Chief Financial O fficer and Reporting Manager’s knowledge,
experience and on-going training in US GAAP and SEC Rules and Regulations.  In doing
so, please tell us the approxima te number of hours spent eac h year attending training
courses focused on US GAAP and SEC Rules.  Please also describe the nature of any US
GAAP audit engagements which these indivi duals participated in including the
approximate number of hours spent on the e ngagements, whether they were directly
involved in US GAAP issues and if so  provide details of those issues.

Onward Choi
NetEase.Com, Inc. September 27, 2011 Page 3

 Notes to the Consolidated Fi nancial Statements, page F-7

 Note 2.  Principal Accounting Policies, page F-11

(m)  Share-based compensation, page F-14

5. We reviewed your response to comment 21 in  our letter dated August 8, 2011.  Reference
is made to your statement that you intend to prevent the employee from bearing the risks
and rewards that are normally associated with  stock ownership.  Pl ease tell us whether
you predominately settle RSU awards in cash when the payment date fair value of the
shares is greater than and less than the grant date fair valu e.  Please also tell us your
consideration of the guidance in ASC 718-10-25-15.    You may contact Adam Phippe n, Staff Accountant, at ( 202) 551-3336 or me at (202)
551-3344 if you have questions regarding comments  on the financial statements and related
matters.  Please contact Angi e Kim, Staff Attorney, at (202) 551-3535 or Mara Ransom,
Assistant Director, at (202) 551- 3264 if you have questions regard ing any other comments.

Sincerely,
    /s/ William H. Thompson

William H. Thompson
Accounting Branch Chief