SecProbe.io

Mail Stop 3561
August 30, 2016

William Lei Ding
Chief Executive Officer
NetEase, Inc.
Building No. 7, West Zone
Zhongg uancun Software Park (Phase II)
No. 10 Xibeiwang East Road, Haidian District
Beijing 100193, People’s Republic of China

Re: NetEase, Inc.
 Form 20-F for Fiscal Year Ended December 31,  2015
Filed April 22 , 2016
File No. 0-30666

Dear Mr. Ding:

We have reviewed your filing an d 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will r espond.  If you do not believe our
comments apply to your facts and circumstances, please  tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

A. Operating Results

Consolidated Results of Operations

Year Ended December 31, 2015 Compared to Year Ended December 31, 2014, page 65

1. Please include a discussion of known trends, demands, commitments, events, or
uncertainties that will have or are reasonably likely to have a material impact on you r
financial condition, operating performance, revenues or income, or result in your liquidity
decreasing or increasing in any material way.  For example, we note net revenues from
the e -mail, e -commerce and others segment increased by 235.7% in 2015 as com pared to
2014 attributed to cross -border e -commerce.  Please discuss the material trends related to
e-commerce.  Please provide similar disclosure regarding your advertising services and
online games services, including a discussion about the lifecycle of significant games.

William Lei Ding
NetEase, Inc.
August 30, 2016
Page 2

 Refer to Item 303 of Regulation S -K and the Commission's Guidance Regarding
Management's Discussion and Analysis of Financial Condition and Results of
Operations, SEC Release No. 34 -48960 .

2. We note the 86.9% increase in net revenues from online game services.   Please provide
additional detail about factors that contributed to the increase in net revenues.   In doing
so, please separately quantify the increase in revenues attributable to mobile games and
the increase in revenue attribut able to the Blizzard Entertainment games.   Please r efer to
Item 5.A of Form 20 -F.

Notes to the Consolidated Financial Statements

3. Concentrations and Risks, page F -21

3. We note your disclosure on page 37 that Blizzard agreed to license to Shanghai Ease Net
certain online computer games with terms of three years.  Further, we note your
disclosure on page 65 that net revenues generated from game licensing represented
12.1%, 12.9% and 9.8% of total net revenues in 2015, 2014 and 2013, respectively.  In
that regard, please tell us what consideration you gave to disclosing the material
concentrations of the online games licensed from Blizzard or tell us why you believe the
disclosure is not required.  In your response please reference ASC 275 -10-50-16 through
50-22.  In your response please also quantify the net revenues generated from Blizzard
online game licensed agreements.

20. Share -based Compensation

(f) Other Option Plan, page F -34

4. Please clarify to us why you did not record compensation expense for options granted in
relation to your other option plans.  In doing so, please describe the vesting terms and
conditions that must be met to achieve the vesting commencement date and explain in
greater detail why achieving such is not probable.  Please also tell us the number of
options granted for tho se plans in 2013, 2014 and 2015.

26. Segment Information

(a) Description of segments , page F -37

5. We note your CODM view and run its business operations based on customer ba se and
homogeneity of products, among other things .  We also note the e-mail, e -commerce and
others segment include a variety of products and services  and the segment net revenues
increased by 235.7% in 2015 as compared to 2014 attributed to e -commerce  cross -border
products as described in the  third paragraph on page 66 .  In that regard, p lease explain to
us what factors you considered in concluding that the products and services in the e -mail,

William Lei Ding
NetEase, Inc.
August 30, 2016
Page 3

 e-commerce and others segment are similar.  Please discuss how you considered
quantitative aspects su ch as margins and growth rates in your analysis.  Refer to ASC
280-10-50-11.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 t he disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; 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.

You may contact Yolanda Guobadia, Staff Accountant,  at (202) 551 -3562, Donna Di
Silvio, Staff Accountant, at (202) 551 -3202  or me at (202) 551 -3344 if you have questions
regarding comments on the financial  statements and related matters.  Please contact Dean
Brazier, Jr., Staff Attorney,  at (202) 551 -3485 or Lisa Kohl, Legal Branch Chief , at (202) 551 -
3252  with any other questions.

Sincerely,

 /s/ William H. Thompson

 William  H. Thompson
Accounting Branch Chief
Office of Consumer Products