SecProbe.io

October 26, 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 Fiscal Year Ended December 31, 2010
Filed June 22, 2011 File No. 0-30666

Dear Mr. Choi:
 We have reviewed your response dated October 13, 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 two in our letter dated September 27, 2011.  In
circumstances where a significant amount of consolidated cash, time deposits and short-
term investments is held by foreign subsidiari es and VIEs, we believe  that disclosure of
whether you would need to accrue and pay ta xes if repatriated a nd your intent not to
repatriate the funds would be necessary fo r an understanding of  your liquidity even
though such disclosure is include d in the financial statements.  As such, if the amount of
cash and time deposits held by PRC subsidia ries and variable interest entities is

Onward Choi
NetEase.Com, Inc. October 26, 2011 Page 2

 significant, please also disclo se that you would need to ac crue and pay withholding and
other taxes if the funds were repatriated and do not intend to repatriate the funds.  Refer
to Item 5.B. of Form 20-F.
 Consolidated Financial Statements

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

2. We reviewed your response to comment four in our letter dated September 27, 2011.
Regarding the US GAAP audit engagement s in which your Acting Chief Financial
Officer participated, please  tell us the approximate number of hours spent on these
engagements.  In addition, as previously requested please elabor ate on your Reporting
Manager’s knowledge, experi ence and on-going training in US GAAP and SEC Rules
and Regulations provided in your response to  comment 14 in our letter dated August 8,
2011.  In doing so, please tell us the appr oximate number of hours spent each year
attending training courses focused on US GAAP and SEC Rules.  Please  also describe the
nature of any US GAAP audit engagement s which this individual participated in
including the approximate number of hours spen t on the engagements, whether they were
directly involved in US GAAP issues and if  so provide details of those issues.

You may contact Adam Phippe n, Staff Accountant, at ( 202) 551-3336 or me at (202)
551-3344 if you have questions regarding our comments or any other questions.

Sincerely,
    /s/ William H. Thompson
 William H. Thompson Accounting Branch Chief