SEC Comment Letter for NetEase, Inc. (NTES, NETTF) (CIK 0001110646) (NTES) — Sep 19, 2018
NetEase, Inc. (NTES, NETTF) (CIK 0001110646)
Date: Sept. 19, 2018 · CIK: 0001110646 · Accession: 0000000000-18-029450
AI Filing Summary & Sentiment
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Letter
September 19 , 2018 William Lei Ding Chief Executive Officer NetEase, Inc. Building No. 7, West Zone, Zhongguancun 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 the Fiscal Year Ended December 31 , 201 7 Filed April 20 , 2018 File No. 0-30666
Dear Mr. Ding :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment s. In our comment s, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to th ese comment s within ten business days by providing the requested information or a dvise us as soon as possible when you will respond. If you do not believe our comment s apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to th ese comment s, we may have additional comments
Note 2. Principal Accounting Policies
(l) Intangible Assets, page F -16
1. Please tell us what consideration you gave to providing the disclosures required by ASC 350-30-50-1, ASC 350 -30-50-2 and ASC 350 -30-50-4.
Note 21. Commitments and Contingencies
(b) Litigation, page F -32
2. Please tell us what consideration you gave to disclosing an estimate of the possible loss or range of loss or a statement that such an estimate cannot be made. Please refer to ASC 450-20-50-4.
William Lei Ding NetEase, Inc. September 19 , 2018 Page 2
Note 22. Dividends, page F -32
3. Please explain to us why the amounts of dividends declared and paid during 2016 and 2017 disclosed in the first paragraph differ from the amounts disclosed in the consolidated statements of cash flows and of shareholders’ equity.
We remind you that the c ompany and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Ta Tanisha Meadows, Staff Accountant at (202) 551 -3322 if you h ave questions regarding our comment s or related matters . Please contact me at (202) 551 -3344 w ith any other questions.
Sincerely,
/s/ William H. Thompson
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September 19 , 2018 William Lei Ding Chief Executive Officer NetEase, Inc. Building No. 7, West Zone, Zhongguancun 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 the Fiscal Year Ended December 31 , 201 7 Filed April 20 , 2018 File No. 0-30666 Dear Mr. Ding : We have limited our review of your filing to the financial statements and related disclosures and have the following comment s. In our comment s, we may ask you to provide us with information so we may better understand your disclosure. Please respond to th ese comment s within ten business days by providing the requested information or a dvise us as soon as possible when you will respond. If you do not believe our comment s apply to your facts and circumstances, please tell us why in your response. After reviewing your response to th ese comment s, we may have additional comments Note 2. Principal Accounting Policies (l) Intangible Assets, page F -16 1. Please tell us what consideration you gave to providing the disclosures required by ASC 350-30-50-1, ASC 350 -30-50-2 and ASC 350 -30-50-4. Note 21. Commitments and Contingencies (b) Litigation, page F -32 2. Please tell us what consideration you gave to disclosing an estimate of the possible loss or range of loss or a statement that such an estimate cannot be made. Please refer to ASC 450-20-50-4. William Lei Ding NetEase, Inc. September 19 , 2018 Page 2 Note 22. Dividends, page F -32 3. Please explain to us why the amounts of dividends declared and paid during 2016 and 2017 disclosed in the first paragraph differ from the amounts disclosed in the consolidated statements of cash flows and of shareholders’ equity. We remind you that the c ompany and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Ta Tanisha Meadows, Staff Accountant at (202) 551 -3322 if you h ave questions regarding our comment s or related matters . Please contact me at (202) 551 -3344 w ith any other questions. Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief Office of Consumer Products cc: Charles Yang , Chief Financial Officer