SecProbe.io

September 16, 2011
 Via E-mail

Jane Jie Sun Chief Financial Officer Ctrip.com International, Ltd. 99 Fu Quan Road Shanghai 200335 People’s Republic of China
Re: Ctrip.com International, Ltd.
 Form 20-F for the Fiscal Year Ended December 31, 2010
Filed on March 31, 2011 File No. 001-33853

Dear Ms. Sun:
 We have reviewed your letter dated September 6, 2011 in connection with the above-
referenced filing 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 may have addi tional comments.  Unless otherwise noted, where
prior comments are referred to they re fer to our letter dated August 3, 2011.
 Item 18.  Financial Statements

 Notes to the Consolidated Financial Statements

 2.  Principal Accounting Policies

 Major variable interest entities, page F-8

1. We note from your response to prior comment 5 that your enforceability conclusions are
based on the legal opinion you received from Commerce & Fi nance Law Offices.  Please
revise your footnote disclosures in future fi lings to discuss management’s and Commerce

 Jane Jie Sun Ctrip.com International, Ltd. September 16, 2011 Page 2
 & Finance’s conclusions regarding the lega lity and enforceability of the contractual
arrangements.
 2. Your response to prior comment 6 indicates  that you will expand your discussion in your
footnotes in future Form 20-F filings.  Pleas e provide us with proposed disclosure that
addresses the concerns noted in prior comment 6, specifically, your ability to consolidate.

Other

3. As previously requested, 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 Christine Da vis, Assistant Chief Account ant, at (202) 551-3408 if you
have questions regarding comments on the financ ial statements and related matters.  Please
contact me at (202) 551-3499 with any other questions.

Sincerely,
   /s/  Kathleen Collins
Kathleen Collins Accounting Branch Chief