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The9 Limited

17 Floor, No. 130 Wu Song Road

Hong Kou District, Shanghai 200080

People’s Republic of China

January 8, 2025

VIA EDGAR

Mr. Rolf Sundwall

Ms. Kate Tillan

Mr. John Dana Brown

Ms. Sonia Bednarowski

Office of Crypto Assets

Division of Corporation Finance

100 F Street, NE

Washington, D.C., 20549

Re: The9 Limited (the “Company”)

    Form 20-F
    for the Fiscal Year Ended December 31, 2023

    Response
    dated August 29, 2024

    File
    No. 001-34238

Dear Mr. Sundwall, Ms. Tillan, Mr. Brown and Ms. Bednarowski,

This letter sets forth the
Company’s responses to the comments contained in the letter dated November 19, 2024 from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) regarding the Company’s annual report on Form 20-F
for the fiscal year ended December 31, 2023 filed with the Commission on April 15, 2024 (the “2023 Form 20-F”)
and the Company’s response submitted on August 29, 2024. The Staff’s comments are repeated below in bold and are followed
by the Company’s responses thereto. All capitalized terms used but not defined in this letter shall have the meaning ascribed to
such terms in the 2023 Form 20-F.

Annual Report on Form 20-F for the
Fiscal Year Ended December 31, 2023

Information on the Company

Business Overview

Cryptocurrency Mining, page 80

 1. Refer to your response to prior comment 2. In your next response letter please provide us a draft of
disclosure that you will include in your next periodic report regarding LGHTSTR Ltd.'s agreement with Fish2Pool, addressing the following
matters:

 · You state that pursuant to the Fish2Pool Agreement the fee "shall be fixed for one year from the
signing of the [Agreement] if [you] can keep its weighted average hash rate in all accounts at above 150 PH/S." Please clarify what
you mean by your disclosure that "if [you] can keep its weighted hash rate in all accounts at above 150 PH/S." For example,
clarify what you mean by "all accounts" and whether you provide all 150PH/S in such accounts.

Securities and Exchange Commission

January 8,
2025

Page 2

Response:

In response to the Staff’s comment,
the Company respectfully proposes to revise the referenced disclosure as follows (page references are made to the 2023 Form 20-F
to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with deletions shown as strike-through,
additions proposed in the Company’s response submitted on August 29, 2024 underlined and further additions proposed in double
underline), subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed.

Page 82:

Mining pool operators

. . .

Mining pool operations in Kazakhstan

We have used two locally registered
mining pools in Kazakhstan.

. . .

In March 2024,
LGHTSTR Ltd. has terminated the agreement. In the same month, our service provider LGHTSTR Ltd. signed the Agreement for the Provision
of Services of Combining the Capacity of Hardware and Software Complex for Digital Mining of Digital Miners and Distribution of Digital
Assets Obtained as A Result of Miners’ Activities, or the Fish2Pool Agreement, with Fish2Pool Kazakhstan Ltd., or Fish2Pool. According
to the Fish2Pool Agreement:

. . .

 1. Fish2Pool’s service fee is 2.5% of the distributed Bitcoin proceeds generated by our mining
                                                               equipment in terms of the block reward, calculated in accordance with the FPPS calculation formula. Fish2Pool’s fee shall be
                                                               paid by us on a daily basis only when we actually begin to engage in digital mining activities. The rate of Fish2Pool’s fee
                                                               shall be fixed as 2.5% for one year from the signing date of the Fish2Pool
                                                               Agreement if we can keep it’s the weighted
                                                               average hash rate in all accounts at above 150PH/S. This implies that the fee rate
                                                               of 2.5% is a base-line rate which has been agreed subject to the condition that NTBC’s connected equipment for all accounts
                                                               reaches a weighted average hash rate of 150PH/S during the one-year period. “Accounts” refer to different wallet
                                                               addresses that may be opened on Fish2Pool to collect mining proceeds from the connected equipment. As of the date of this annual
                                                               report, NBTC has opened [**] wallet to collect mining proceeds. The weighted average hash rate of NBTC’s connected equipment
                                                               [have reached/have not reached] full 150 PH/S for one year from the signing date of the Fish2Pool Agreement. As a result, the
                                                               base-line fee rate of 2.5% [has been/has not been] subject to the adjustment mechanism. Specifically, the parties agreed that if the
                                                               statistical probability of finding a new block for Bitcoin mining by NBTC’s connected equipment during any three-month period
                                                               in the one-year period falls below 80% from the normally expected levelstera hash level of 100% working miners, then
                                                               theThe rate will be increased from 2.5% to 3.0% if the statistical
                                                               probability of finding a new block for Bitcoin mining by our equipment during past three months falls below 80%. This
                                                               additional condition relates to the stability of NBTC’s equipment performance, which may be affected by unstable internet
                                                               connection in the data center hosting NBTC’s equipment that obstructs submission of calculation results generated by such
                                                               equipment to the network. For one year from the signing date of the Fish2Pool Agreement, fee rate [has been/has not been] increased
                                                               to 3.0%.

    2

Securities and Exchange Commission

January 8,
2025

Page 3

. . .

 · Your disclosure that the rate will be fixed for one year if you keep Fish2Pool's weighted average hash
rate in all accounts at or above 150PH/S appears to be inconsistent with your disclosure that "the rate will be increased from "2.5
to 3.0% if the statistical probability for finding a new block for Bitcoin mining by [y]our equipment during the past three months falls
below 80%." Please revise for clarity and consistency.

Response:

Please refer to the Company’s
response to the first bullet point above.

 · Describe the termination provisions related to Fish2Pool terminating the agreement.

Response:

In response to the Staff’s comment,
the Company respectfully proposes to revise the referenced disclosure as follows (page references are made to the 2023 Form 20-F
to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with deletions shown as strike-through,
additions proposed in the Company’s response submitted on August 29, 2024 underlined and further additions proposed in double
underline), subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed.

    3

Securities and Exchange Commission

January 8,
2025

Page 4

Page 82:

Mining pool operators

. . .

Mining pool operations in Kazakhstan

We have used two locally registered
mining pools in Kazakhstan.

. . .

In March 2024,
LGHTSTR Ltd. has terminated the agreement. In the same month, our service provider LGHTSTR Ltd. signed the Agreement for the Provision
of Services of Combining the Capacity of Hardware and Software Complex for Digital Mining of Digital Miners and Distribution of Digital
Assets Obtained as A Result of Miners’ Activities, or the Fish2Pool Agreement, with Fish2Pool Kazakhstan Ltd., or Fish2Pool. According
to the Fish2Pool Agreement:

. . .

 · We have the right to terminate the agreement in case Fish2Pool loses its operating license in accordance
with the laws of Kazakhstan, including the revocation, annulment and/or other cancellation of accreditation
of Fish2Pool as a digital mining pool in Kazakhstan. We also have the right to terminate
the agreement for any reason and any time, provided that we have fulfilled all financial obligations for services rendered under the agreement.
Fish2Pool does not have an explicit right to terminate the agreement during the term of the agreement. However, Fish2Pool has the right
to unilaterally suspend the provision of services without any liability to us if Fish2Pool’s equipment loses technical ability to
perform pool services.

. . .

 · Disclose the material terms of NBTC's agreement with LGHTSTR Ltd., as we note your statement that the
Fish2Pool agreement was entered into by LGHTSTR Ltd., your service provider.

    4

Securities and Exchange Commission

January 8,
2025

Page 5

Response:

In response to the Staff’s comment,
the Company respectfully proposes to revise the referenced disclosure as follows (page references are made to the 2023 Form 20-F
to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with deletions shown as strike-through,
additions proposed in the Company’s response submitted on August 29, 2024 underlined and further additions proposed in double
underline), subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed.

Page 82:

Mining pool operators

. . .

Mining pool operations in Kazakhstan

We
have used two locally registered mining pools in Kazakhstan through agreements between
our service provider LGHTSTR Ltd., each locally registered mining pools in Kazakhstan. According
to the agreement by and between LGHTSTR Ltd. and NBTC, NBTC is bound by the terms of the agreements negotiated by LGHTSTR Ltd. on NBTC’s
behalf.

. . .

Financial Statements

Note 2. Principal Accounting Policies

(9) Cryptocurrencies, page F-16

 2. We note that the proposed disclosure in your response to prior comment 9 is not consistent with the
definition of a current asset in ASC 210-10-20. Accordingly, we re-issue our prior comment. Please revise your disclosure in future filings
to state, if true, that your cryptocurrencies are reasonably expected to be realized in cash or sold or consumed during the normal operation
cycle of your business.

Response:

In response to the Staff’s comment,
the Company respectfully proposes to revise the referenced disclosure as follows (page references are made to the 2023 Form 20-F
to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with deletions shown as strike-through,
additions proposed in the Company’s response submitted on August 29, 2024 underlined and further additions proposed in double
underline), subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed.

    5

Securities and Exchange Commission

January 8,
2025

Page 6

Page F-16:

<9> Cryptocurrencies

Cryptocurrencies
are classified on the Group’s Consolidated Balance Sheets as current assets due to the Group’s ability to sell them in a highly
liquid marketplace, as our cryptocurrencies are reasonably expected
and its intention to liquidate sell its Cryptocurrencies to be realized
in cash and/or consumption of its Cryptocurrencies for the Group’s or
sold or consumed during the normal operation cycle of our business to support operations when needed.

Pledged
Cryptocurrencies are classified on the Group’s Consolidated Balance Sheets as Cryptocurrencies, restricted, which will be released
within one year are included in the current assets, as they are reasonably expected
to be realized in cash or sold or consumed during the normal operation cycle of our business. and Cryptocurrencies,
restricted, which will be released over one year are included in the non-current assets.

(12) Revenue recognition, page F-17

3. Your response to prior comment 10 did not respond fully to our comment. We reissue the prior comment
in part. References to the MOU are to Annex A of your October 20, 2023 response letter. You characterized the MOU as being your mining
agreement with the pool operator and you told us that the agreement is terminable at any time by either party without compensation. Please
respond to the following:

 · While we note your assertion that the arrangement with Binance is ongoing, clarify for us whether the
MOU legally terminated on July 7, 2022. Refer to Article 12c which appears to indicate that the agreement terminated on July 7,
2022 (365 days after its signing).

Response:

The Company respectfully advises the
Staff that the Company entered into the MOU with Binance to utilize their mining pools on July 7, 2021, at a time when mining operations
were legally permissible in China. It is pertinent to note that at that time, most mining pool providers in China, including Binance,
do not require the signing and execution of a formal agreement for the utilization of their mining pools. Instead, customers are able
to utilize their services online through these mining pool providers’ websites and/or apps. The cooperation relationship was sustained
by a mining machine owner’s continued contribution of computing power to the mining pools, with rewards distributed to the mining
machine owner accordingly. Specifically, as long as a mining machine owner continue to contribute its computing power to the mining pool,
the mining pool will continue to reward to that mining machine owner based on the share of the computing power contributed to that mining
pool. When a mining machine owner stops the mining activities or shifts to another mining pool, the mining pool will reward the mining
machine owner’s share up to the last computing power contributed to that mining pool. After that, the cooperation between the mining
machine owner and the mining pool provider will be deemed as finished.

    6

Securities and Exchange Commission

January 8,
2025

Page 7

The MOU with Binance was primarily
signed for business development purposes. When the Company execute the MOU with Binance, procuring Bitcoin mining machines was challenging
due to high demand and low supply. Partnering with Binance, then China’s largest cryptocurrency company, enabled the Company to
secure better deals with vendors of Binancevarious mining machines, as cooperation with a reputable partner demonstrated
the Company’s commitment to expanding mining capacity. Both parties understood that the MOU served these specific purposes rather
than governing long-term mining cooperation between the Company and Binance. This aligns with industry practices in China where customers
retain the right to unilaterally cease mining activities at any time.

Consequently,
as the Company is still utilizing Binance’s mining pools, the Company believe that the collaboration with Binance
is still ongoing. However, theThe Company hereby confirms that the MOU should
have been legally terminated on July 7, 2022 in accordance with Article 12c. However,
both parties continued to cooperation under the MOU up until September 2024. As of the date of this letter, the Company has no cooperation
with Binance’s mining pools. In addition, as the MOU was primarily signed for busi