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        August 15, 2008  Jane Jie Sun  Chief Financial Officer Ctrip.com International, LTD. 99 Fu Quan Road Shanghai, PRC, 200335
 Re: Ctrip.com International, LTD.
 Form 20-F for the Fiscal Year Ended December 31, 2007
Filed on April 29, 2008
 File No. 001-33853

Dear Ms. Sun:

We have reviewed the above-referenced filing and have the following comments.
Please note that we have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your document.
If indicated, we think you should revise your document in response to these comments.
If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 20-F for the Year Ended December 31, 2007

 Item 5. Operating and Financial Review and Prospects

 Results of Operations, page 41

1. We note that the primary driver for the increase in your cost of revenue, product
development, sales and marketing, and ge neral and administrative costs was an

Jane Jie Sun
Ctrip.com International, LTD.
August 15, 2008 Page 2
increase in personnel.  As this inform ation may be beneficial in explaining
material increases in cost of revenue and/or operating expense, tell us how you
considered quantifying the increase in headcount by department in your MD&A
discussion pursuant to Item 5A of Form  20-F and Section III. D of SEC Release
33-6835.
 Liquidity and Capital Resources, page 44

 2. We note an apparent trend in a slowing of your accounts receivable turnover over
from fiscal 2006 to fiscal 2007 in comparis on to the increase in revenue.  Please
provide us with analysis th at explains the reasons and reasonably likely impact on
liquidity and/or revenue recognition.  If  material to an understanding of your
operations and liquidity tell us how you considered explaining any material
trends, events or uncertainties associated  with your collections and receivable
balances in your liqui dity discussion.
 Note 2. Principal Accounting Policies

 Accrued Liability for Customer Reward Program, page F-12

 3. We also note from your disclosure on page 39 that you estimate redemption when
recording the accrued liability for customer reward programs and if actual redemption differs significantly from your es timate, it will result in an adjustment
to the liability and corresponding expense.  Please describe the nature of your
estimation process in further detail and pr ovide us with adjustments recorded for
differences in actual redemption versus estimated redemption for each period presented.
 Note 4. Long-term Deposits, page F-22

 4. We note that you have long-term deposits that are primarily comprised of (1)
deposits to airline companies to obtain bl ank air tickets for sales to customers and
(2) deposits to local Travel Bureau as a pl edge for insurance of traveler’s safety.
Describe the nature of these deposits in further detail, including the terms of your
deposit agreements and your de termination of the patter n of expense recognition.
In addition, tell us how you considered disclosing the policy for deferral and
amortization pursuant to Rule 5-02(17) of Regulation S-X.
 Certifications in Exhibits 12.1 and 12.2

 5. We note that the identification of the cer tifying individual at  the beginning of
each of the certifications required by Exchange Act Rule 13a-14(a) also includes
the title of the certifying i ndividual.  In future filings , the identification of the

Jane Jie Sun
Ctrip.com International, LTD.
August 15, 2008 Page 3
certifying individual at the beginning of the certifications should be revised so as
not to include the individual’s title.

* * * * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
 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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a
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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Jane Jie Sun
Ctrip.com International, LTD. August 15, 2008 Page 4
You may contact Melissa Feider, Sta ff Accountant, at (202) 551-3379, Patrick
Gilmore, Staff Accountant, at (202) 551-3406, or me at (202) 551-3499 if you have
questions regarding the above comments.
       S i n c e r e l y ,           Kathleen Collins
Accounting Branch Chief