SecProbe.io

Mail Stop 4561
December 1 6, 2016

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 Fiscal Year Ended December 31, 2015
Filed April 22, 2016
File No. 001 -33853

Dear Ms. Wang :

We have reviewed your letter dated November 8, 2016  in connection wi th the above -
referenced filing  and have the following comment.  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 requeste d information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply 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 these comments, we may have additional comments.   Unless otherwise noted, where
prior comments are referred to they refer to our letter dated October 25 , 2016 .

Form 6 -K Filed Se ptember 6, 2016

1. There is a presumption in ASC 323 -10-15 that ownership of less than 20% of the voting
stock of an investee should not be accounted for under the equity method unless th ere is
evidence that supports the company’s ability to exercise significant influence over the
investee.   Please explain further the following as it relates to your analysis under ASC
323-10-15:

 In your response to comment 4 in your October 14, 2016 lette r, you state that the
Founders Group will have the right to appoint two directors to Homeinns board so
long as the Founders collectively own 15% of Homeinns’ outstanding ordinary
shares.   However, it appears that Ctrip, and not the Founders Group, holds th e equity

Xiaofan Wang
Ctrip.com International, Ltd.
December 1 6, 2016
Page 2

 interest in Homeinns.   Tell us how the Founders Group meets the requirements to
appoint Homeinns’ directors;

 Describe how the four individual Founders select directors to appoint to the
Homeinns board and what, if any, legal agreements govern thi s selection process;

 Explain how the rights of the Founders Group to appoint Homeinns’ board members
support  your assertion that Ctrip has the ability to exercise significant influence over
Homeinns.   In this regard, we note that the four individual Founders:
o in the aggregate, own less than 5% of Ctrip’s outstanding ordinary shares;
o do not hold a majority of the votes on Ctrip’s board of directors; and
o have a right to appoint three directors to the Ctrip’s board that is subject to
approval of a majorit y of the company’s independent directors ; and

 Tell us how much of the “equity  in income/ (loss) of affiliates” income statement  line
item rela tes to  Homeinns for each of the fiscal years 2014 and 2015, and to date in
fiscal 2016  and how m uch of such amounts relate to the  equity pick -up versus the
basis dif ference.   Also, tell us whether the company believes the effects of the
investment in Homeinns is material  to your financial statements .

You may contact Frank Knapp, Staff Accountant at (202) 551 -3805  if you have questions
regarding these comments.  If you require further assistance, do not hesita te to contact me at
(202) 551 -3499 .

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Branch Chief
Office of Information Technologies
and Services

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