SecProbe.io

March 11, 2013

Via E -mail
Mr. George Lai
Chief Financial Officer
The9 Limited
Building No. 3, 690 Bibo Road
Zhang Jiang Hi -Tech Park
Pudong New Area, Pudong
Shanghai 201203
People’s Republic of China

Re: The9 Limited
 Form 20-F for the Fiscal Year Ended December 31, 2011
Filed March 22, 2012
File No. 001 -34238

Dear Mr. Lai:

We have reviewed your letter dated February 6, 2012  in connection with the above -referenced
filing s 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 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 comment s, we may have  additional comments.   Unless otherwise noted , where prior comments
are referred to they refer to our letter dated January 23, 2013 .

Form 20 -F for the Fiscal Year Ended December 31, 2011

Item 18.  Financial Statements

Note 19.  Refund of WoW Game Points, page F -49

1. Please explain further  the following as it relates to  your response to  prior  comment 7 :

 You state  that the company will refund holders of activated but unconsumed cards who
“advance appropriate claims.”  Te ll us how you determine what constitutes an
“appropriate ” claim ;
 Explain  how you determine the “unconsumed ” balance of such cards.  In this regard, tell us

Mr. George Lai
The9 Limited
March 11, 2013
Page 2

 how you obtain information reg arding the amount o f points consumed by the player after
your loss of the WoW license ;
 To the extent you are unable to obtain such usage information, explain  further how you can
reasonably det ermine the amount due  to the player upon receipt of an appropriate claim ;
 Tell us the amount o f claims, if any, processed to date on activated but unconsumed point
cards  since your loss of the WoW license ; and
 If no claims have  yet been processed, to the extent you are able to obtain usage information
for these cards , tell us how you use this information  to determine wh ether any income  can
be recognized relating to these activated but unconsumed point cards .

2. We note your response to our prior comment 9 as it relates to your consideration to recognize
breakage for activated but unconsumed point cards .  Tell us how you considered the passage o f
time since the loss of the WoW  license , in connection with the fact that it appears  no material
refunds have been paid  to date on the  activated but unconsumed game points , in your analysis
of the liability as of December 31, 2011 and 2012.   In this rega rd, tell us whether you continue
to believe that you do not have sufficient  factual information to determine that the balance , or a
portion thereof , could be considered remote for redemption purposes and how you reached this
conclusion.

Note 28.  Commitments and Contingencies

28.3 Contingencies, page F -59

3. We note your response to our prior comment 10.   Your proposed disclosure uses terminology
such as “highly unlikely ,” which does not comply with the guidance in ASC 450.   Explain
further what you mean by “highly unlikely” and  further  revise your disclosures to use
terminology that complies with ASC 450 -20-50 (e.g. probable, reasonably possible or remote).
Please provide the revised disclosures that you intend to include in your n ext filing.

You may contact Megan Askt, Staff Accountant , at (202) 551 -3407 i f you have questions
regarding comments on the  financial statements and re lated matters.   If you require further assistance,
do not hesitate to contact me at (202) 551 -3499.

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Branch Chief

cc:   Via e -mail
 Andrew Han – The9 Limited