SecProbe.io

July 15, 2019
Charles Yang
Chief Financial 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, 2018
Filed April 26, 2019
File No. 000-30666
Dear Mr. Yang:
            We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2018
Financial Statements
Notes to the consolidated financial statements
20. Commitments and Contingencies
(b) Litigation, page F-34
1.We note you reached a settlement agreement with PUBG in March 2019 regarding the
complaint alleging copyright and trademark infringement as it relates to your mobile
games, Rules of Survival and Knives Out.  Please describe to us your accounting for the
settlement and period of recognition.  Further, tell us what consideration you gave to
providing disclosure when describing any known trends or uncertainties with respect to
revenues from Knives Out and Rules of Survival pursuant to Item 303(a) of Regulation S-
K.  In this regard we note your disclosure that the growth in net revenues from mobile
games mainly resulted from games such as Knives Out which gained popularity over the

 FirstName LastNameCharles Yang
 Comapany NameNetEase, Inc.
 July 15, 2019 Page 2
 FirstName LastName
Charles Yang
NetEase, Inc.
July 15, 2019
Page 2
course of 2018.
            We remind you that the company 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 Tony Watson, Staff Accountant, at (202) 551-3318 or Donna Di
Silvio, Staff Accountant, at (202) 551-3202 if you have questions regarding comments on the
financial statements and related matters.  Please contact Scott Anderegg, Staff Attorney, at 202-
551-3342  or Lilyanna Peyser, Special Counsel, at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products