SecProbe.io

September 5 , 2014

Via E -mail
Xiaofan Wang
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, 2013
Filed March 28, 201 4
File No. 001 -33853

Dear Ms. Wang :

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 lett er within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have  additional comments.

Form 20 -F for the Fiscal Year Ended December 31, 2013

Item 5. Operating and Financial Review and Prospects

A. Operating Results

Major Factors Affecting Our Results of Operations, page 35

1. During your recent earnings calls,  you reference a “mobile transaction value”
measure.   Corresponding quarterly and peak daily values, and a breakdown of these
values for accommodation reservations and ticketing were also provided.   With a view
towards fut ure disclosure, please tell us what consideration you gave to including the
transaction value for each of the platforms over which your products an d services are
sold, and providing  a discussion regarding the significance of the mobile transaction

Xiaofan Wang
Ctrip.com International, Ltd.
September 5, 2014
Page 2

 value me asure to the management of your business.  Also , tell us whether  you utilize any
other  metrics in the management of your business, and what consideration you gave to
disclosing these metrics.

We urge all persons who are responsible for the accuracy and a dequacy of the disclosure
in the filing to be certain that the filing 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 a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the a dequacy 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 a s a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Laura Veator, Staff Accountant , at (202) 551 -3716,  Ivan Griswold,
Staff Attorney, at (202) 551 -3853 , or Barbara C. Jacobs, Assistant Director, at (202) 551 -3735 if
you have any questions regarding our comment.   If you require further assistance, do not hesitate
to contact me at (202) 551 -3488 .

Sincerely,

 /s/ Stephen Krikorian

Stephen Krikorian
Accounting Branch Chief