SecProbe.io

September 10, 2013

Via E -mail
Jenny Wenjie Wu
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, 2012
  Filed March 29 , 2013
  File No. 1 -33853

Dear Ms. Wu:

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we m ay
better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts an d circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

General

1. We note language on your website during the past six months advertising flights o r
vacation packages to Havana, Cuba; Khartoum, Sudan and Damascus, Syria.   Cuba,
Sudan and Syria are designated by the U.S. Department of State as state sponsors of
terrorism and are subject to U.S. economic sanctions and export controls.   Please describe
to us the nature and extent of your past, current, and anticipated contacts with Cuba, Syria
and Sudan, if any, whether through subsidiaries, affiliates, alliance partners or other
direct or indirect arrangements.

In this regard, we note your disclosu re on page 29 that you sell tickets “as an agent” for
many airlines including Lufthansa and Air France -KLM.   Lufthansa is a member of Star
Alliance, an airline alliance.   The Star Alliance website indicates that Lufthansa offers

Jenny Wenjie Wu
Ctrip.com International , Ltd.
September 10, 2013
Page 2

 flights servicing Khartoum,  Sudan and that other alliance members offer flights servicing
Damascus, Syria.   Air France -KLM is a member of SkyTeam, an airline alliance.   The
SkyTeam website indicates that Air France -KLM offers flights servicing Havana,
Cuba.   Your response should des cribe any information, services, products or technology
you have directly or indirectly provided to or received from Cuba, Sudan or Syria, and
any agreements, commercial arrangements, or other contacts you have had with the
governments of these countries o r entities controlled by their governments.

2. Please discuss the materiality of any contacts with Cuba, Sudan and Syria described in
response to the foregoing comment and whether those contacts constitute a material
investment risk for your security holders .  You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets, and
liabilities for the last three fiscal years and the subsequent interim period.   Also, address
materiality in terms of qualitative factors that a reasonable investor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value.   Various state and municipal
governments, universities , and other investors have proposed or adopted divestment or
similar initiatives regarding investment in companies that do business with U.S. -
designated state sponsors of terrorism.   Your materiality analysis should address the
potential impact of the inve stor sentiment evidenced by such actions directed toward
companies that have operations associated with Cuba, Sudan and Syria.

We urge all persons who are responsible  for the accuracy and adequacy of the disclosure
in the filing to be certain that the fil ing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to the company’s disclosure, they are responsible for the
accuracy  and adequacy of the disclosures they have made.

In responding to our comments, 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.

Jenny Wenjie Wu
Ctrip.com International , Ltd.
September 10, 2013
Page 3

 Please contact Daniel Leslie, Staff Attorney, at (202) 551 -3876  or me at (202) 551 -3470
if you have any questions about the comments or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecil ia Blye , Chief
         Office of Global Security Risk

cc:  Barbara Jacobs
  Assistant Director
 Division of Corporation Finance

 Z. Julie Gao, Esq.
Skadden, Arps, Slate, Meagher & Flom