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August 11, 2010
 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, 2009 Filed on February 3, 2010
 Forms 6-K Filed February 3, 2010 and May 12, 2010
File No. 001-33853

Dear Ms. Sun:
 We have reviewed your filings and 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 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 the Fiscal Year Ended December 31, 2009

Item 3.  Key Information

D.  Risk Factors,  Risks Related to Our Company

“We face a greater risk of doubtful accounts . . . ” page 14

1. Please tell us what consideration you gave to providing quantitative disclosure regarding
the percent of your revenues derived from co rporate customers so that investors might
better understand the extent of the risk pos ed to your operations by doubtful accounts.

 Jane Jie Sun
Ctrip.com International, LTD. August 11, 2010 Page 2  Item 6.  Directors, Senior Management and Employees

 A. Directors and senior  management, page 44

2. It appears that certain of your directors may be serving in this capacity pursuant to
arrangements or understandings with third pa rties as indicated in  your articles of
association.  Please tell us whether any of your directors or senior management was
selected pursuant to any such arrangement or  understanding and, if so, what consideration
you gave to disclosing this.  Refe r to Item 6.A.5 of Form 20-F.
 E.  Share Ownership, page 50

3. In future filings, please identify the indivi dual(s) with voting and/or dispositive power
over the entities listed in th e share ownership table.
 Item 10.  Additional Information

 C. Material Contracts, page 58

4. Please tell us whether you have entered into any material contracts within the two years
immediately preceding the date of your annual re port.  It is unclear from your disclosure
whether you have entered into any such contracts.  If you have, it does not appear that your disclosure complies with the requirement to include in this section a summary of
any such contracts, including the general na ture of the contract, terms and conditions,
dates and parties to the c ontract.  Please advise.

Item 11. Quantitative and Qualitative Di sclosures About Market Risk, page 63

5. We note from your disclosures th at the Company is exposed to market risk for changes in
foreign currency exchange rates.  Given th at foreign currency exchange gains/losses
appear to be material to net income, please tell us how you believe your disclosures meet
the requirements of one of the quantitative disclo sure alternatives described in  Item 11 of
Form 20-F and Item 305(a) of Regulation S-K.
 Item 18.  Financial Statements

Note 10. Taxation, page F-25

6. We note that you receive various preferential tax rates.  Tell us the aggregate dollar per
share effect on earnings for a ll periods presented and, if material, how you considered
disclosing this information pursuant to SAB Topic 11C.

 Jane Jie Sun  Ctrip.com International, LTD. August 11, 2010 Page 3  Forms 6-K Filed February 3, 2010 and May 12, 2010

7. We note from your Q1 earnings call that you r estimated annual tax rate will be between
21% and 23% for fiscal 2010, of which 6% of th is rate is attribut able to stock based
compensation.  However, we note that your non-GAAP financial measures presented in
your earnings releases do not reflect any tax effect for excluding stock based compensation.  Tell us if you considered presenting a tax effect of stock based
compensation expense in your earnings releases .  For guidance on this matter, please see
Question 102.11 of our Compliance and Di sclosure Interpretations on Non-GAAP
Financial Measures upd ated on January 15, 2010.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Melissa Feid er, Staff Accountant, at ( 202) 551-3379 or me if you have
questions regarding comments on th e financial statements and rela ted matters.  Please contact
Ryan Houseal, Staff Attorney, at (202) 551-3105 or Maryse Mills-Apenteng, Special Counsel at
(202) 551-3457 with any other questions.

Sincerely,

Kathleen Collins Accounting Branch Chief