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Correspondence

 [Letterhead of The9 Limited]

December 17, 2012

 VIA EDGAR AND E-MAIL

 Kathleen Collins, Accounting Branch Chief

Megan Askt, Staff Accountant

 Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

 Re: The9 Limited (the “Company”)

 Form 20-F for the fiscal year ended
December 31, 2011

 Filed March 22, 2012

 File No. 001-34238

 Dear Ms. Collins and Ms. Askt:

This letter sets forth our responses to the comments contained in the letter dated November 20, 2012 from the Staff of the Commission
(the “Staff”) regarding our annual report on Form 20-F for the year ended December 31, 2011 (the “Form 20-F”). For ease of reference, we have set forth the Staff’s comments and our response for each item below.

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

Item 1A. Risk Factors

 General

1.
As a public company, your auditor is required by law to undergo regular Public Company Accounting Oversight Board (PCAOB) inspections to assess its compliance
with U.S. law and professional standards in connection with its audits of financial statements filed with the SEC. The PCAOB, however, is currently unable to inspect the audit work and practices of your auditor (see
http://pcaobus.org/International/Inspections/Pages/IssuerClientsWithoutAccessList.aspx). As a result of this obstacle, investors in U.S. markets who rely on your auditor’s audit reports are deprived of the benefits of PCAOB inspections of
auditors. Therefore, please state this fact under a separate risk factor heading. Explain that this lack of inspection prevents the PCAOB from regularly evaluating your auditor’s audits and its quality control procedures.

 The Company respectfully advises the Staff that it duly notes the fact that the benefits of
PCAOB inspections of auditors are not available to investors in U.S. markets who rely on the auditor’s audit reports included in the Company’s annual report on Form 20-F. In response to the Staff’s comment, the Company proposes to
enhance its disclosure by including the following disclosure as a separate risk factor under “Item 3. Key Information — D. Risk Factors” of its future annual reports on Form 20-F:

The audit report included in this annual report is prepared by auditors who are not inspected by the Public Company Accounting
Oversight Board and, as such, you are deprived of the benefits of such inspection.

 Our independent registered public
accounting firm that issues the audit reports included in our annual reports filed with the US Securities and Exchange Commission, as auditors of companies that are traded publicly in the United States and as a firm registered with the US Public
Company Accounting Oversight Board (United States) (“the “PCAOB”), is required by the laws of the United States to undergo regular inspections by the PCAOB to assess its compliance with the laws of the United States and professional
standards. Because our auditors are located in the Peoples’ Republic of China, a jurisdiction where the PCAOB is currently unable to conduct inspections without the approval of the Chinese authorities, our auditors are not currently
inspected by the PCAOB.

 Inspections of other firms that the PCAOB has conducted outside China have identified deficiencies in
those firms’ audit procedures and quality control procedures, which may be addressed as part of the inspection process to improve future audit quality. This lack of PCAOB inspections in China prevents the PCAOB from regularly evaluating
our auditor’s audits and its quality control procedures. As a result, investors may be deprived of the benefits of PCAOB inspections.

 The inability of the PCAOB to conduct inspections of auditors in China makes it more difficult to evaluate the effectiveness of our auditor’s audit procedures or quality control procedures as
compared to auditors outside of China that are subject to PCAOB inspections. Investors may lose confidence in our reported financial information and procedures and the quality of our financial statements.

Item 5. Operating and Financial Review and Prospects

Critical Accounting Policies, page 47

2.
Considering your disclosures regarding the risks and uncertainties of doing business through VIE contractual arrangements in the PRC, along with the various
factors considered when consolidating such entities, tell us your consideration to include a discussion of your consolidation policy in your critical accounting policy disclosures. In this regard, we refer you to your response letter dated
December 16, 2010 (comment 1) where you acknowledged the guidance in Section V of SEC Release No. 33-8350 and indicted that you would include your consolidation policy as it relates to your VIEs in your future critical accounting policy
disclosures. Please include in your response your proposed revised disclosures.

 The Company respectfully advises the Staff that it included the disclosure noted below
regarding the Company’s policy with respect to the consolidation of financial results of its variable interest entities (“VIEs”), as indicated in the Company’s response letter dated December 16, 2010 (comment 1), immediately
preceding the subsection headed “Item 5. Operating and Financial Review and Prospects — A. Operating Results — Critical Accounting Policies” on pages 46-47 of its annual report on Form 20-F filed on March 22, 2012.

 In response to the Staff’s comment, the Company plans to further expand its prior disclosure on VIEs in future filings as
follows with the proposed additional disclosure in italics:

 Consolidation of Variable Interest Entities, or VIEs.

 PRC laws and regulations, including the GAPP Circular, currently prohibit or restrict foreign ownership
of Internet-related businesses. The Company believes, consistent with the view of our PRC legal counsel, that the Company’s current structure complies with these foreign ownership restrictions. Specifically, we operate our business through
Shanghai IT and Huopu Cloud and have entered into a series of contractual arrangements with Shanghai IT and Huopu Cloud and their equity owners. See the contractual arrangements set forth in “Item 7. Major Shareholders and Related Party
Transactions — B. Related Party Transactions.” As a result of these contractual arrangements, we are entitled to receive service fees for services provided to Shanghai IT and Huopu Cloud for an amount determined at our discretion, up to
90% of PRC entities’ profits. In addition, the equity owners of record for these entities have pledged all their equity interests in the VIEs to us as collateral for all of their payments due to the WOFE and to secure performance of all
obligations of the VIEs and their shareholders under various agreements. In addition, the agreements provide that any dividend distributions made by the VIEs, if any, are required to be deposited in an escrow account over which we have exclusive
control. Moreover, through the Call Option Agreements and Shareholder Voting Proxy Agreements, each shareholder of the VIEs granted WOFE an irrevocable power of attorney to act on all matters pertaining to the VIEs. As a result of the totality of
these arrangements, we have both the power to direct activities that most significantly impact the VIEs economic performance and the obligation to absorb losses of or right to receive benefits from the VIE that are significant to Shanghai IT and
Huopu Cloud. As a result, we concluded we are the primary beneficiary of Shanghai IT and Huopu Cloud and as such Shanghai IT and Huopu Cloud are consolidated VIEs of our company.

 The GAPP Circular reiterates and reinforces the long-standing prohibition
of foreign ownership of Internet-related publication businesses via direct, indirect or disguised methods. However, it is not clear whether the regulatory authority of GAPP applies to the regulation of ownership structures of online game companies
based in China and online game operation in China. In addition, the GAPP Circular does not specifically invalidate VIE agreements, and we are not aware of any online game companies adopting similar contractual arrangements as ours having been
penalized or ordered to terminate such arrangements since the GAPP Circular first became effective. Therefore, we believe that our ability to direct the activities of Shanghai IT that most significantly impact our economic performance is not
affected by the GAPP Circular. Any changes in PRC laws and regulations that affect our ability to control Shanghai IT and Huopu Cloud might preclude us from consolidating Shanghai IT and Huopu Cloud in the future. See “Item 3. Risk factors
— D. Risks Related to Our Corporate Structure — PRC laws and regulations restrict foreign ownership of Internet content provision, Internet culture operation and Internet publishing licenses, and substantial uncertainties exist with
respect to the application and implementation of PRC laws and regulations.

 In response to the Staff’s comment, the
Company proposes to further enhance its disclosure by disclosing such information under, rather than preceding, the subsection headed “Item 5. Operating and Financial Review and Prospects — A. Operating Results — Critical Accounting
Policies” of its future annual reports on Form 20-F.

 Results of Operations, page 52

3. Please describe further the key metrics that impact your business. In this regard, tell us your consideration to disclose, for
example, the average number of users, the number of paying players, the average revenue per player, and/or the average period that a player typically plays the game and include a discussion that correlates these metrics to changes in your results of
operations. It appears that this would be important information to the users of your financial statements since users are a critical component of your business. In addition, please clarify whether there are any other operational statistics and usage
patterns monitored by the company which affect your results of operations. We refer you to Section III.B of SEC Release 33-8350 for guidance.

 In response to the Staff’s comment, the Company proposes to enhance its disclosure by adding the information related to the average quarterly paying users and average quarterly revenue per paying
user information. Specifically, the Company proposes to replace in its entirety the current disclosure on Page 53 under “Item 5. Operating and Financial Review and Prospects — A. Operating Results — Results of Operations — Year
2011 Compared to Year 2010 — Revenue” with the proposed disclosure below in its annual report on Form 20-F for the fiscal year ending December 31, 2012:

 Online Game Services. Our revenues from our online game services increased by 2.4% from RMB106.5 million in 2010 to RMB109.0 million (US$17.3 million) in 2011 primarily due to the increase in
revenues from TV games, web games and social games.

 Our revenues from TV games increased from RMB3.8 million in 2010 to RMB9.2 million (US$1.5
million) in 2011. This increase was primarily due to an increase in our average quarterly paying user from 62,013 in 2010 to 124,536 in 2011 and an increase in our average quarterly revenue per paying user from RMB13 in 2010 to RMB19 in 2011, both
in turn due to continuous expansion in our TV game platform and more quality games launched in 2011. Quarterly paying user refers to the number of users who purchase virtual currency at least once for our online games during a quarter. Average
quarterly paying user is the average of quarterly paying users for each of the four quarters during a year. Quarterly revenue per paying user refers to our revenues from online games during a given quarter divided by the number of the quarterly
paying users. Average quarterly revenue per paying user is the average of quarterly revenues per paying users for each of the four quarters during a year.

 Our revenues from PC games decreased from RMB101.8 million in 2010 to RMB94.6 million (US$15.0 million) in 2011, primarily due to a decrease in our average quarterly paying user from 116,203 in 2010 to
113,507 in 2011 and a decrease in our average quarterly revenue per paying user from RMB234 in 2010 to RMB215 in 2011. The average quarterly revenue per paying user of our PC games is significantly higher than that of our TV games because the PC
game players are mostly teenagers with higher spending power while the TV game players are mostly children and elderly people with lower spending power.

 Liquidity and Capital Resources, page 56

4.
We note from various disclosures throughout the filing that restrictions on currency exchange may limit your ability to distribute funds outside of China. Please
consider revising your disclosures here to include a discussion of these restrictions and how they impact your ability to pay dividends and meet your cash obligations outside of China. We refer you to Item 5.B.1(b) of Form 20-F. Also, include a
discussion of how earnings flow through the corporate structure, describing how funds are transferred from your PRC subsidiaries and consolidated affiliated entities to your entities outside of the PRC. Please include in your response your proposed
revised disclosure.

 In response to the Staff’s comment, the Company proposes to enhance its disclosure by
including the following disclosure under the subsection headed “Item 5. Operating and Financial Review and Prospects — B. Liquidity and Capital Resources — Cash Flow and Working Capital” in its future annual reports on Form 20-F:

 We are a holding company and conduct our operations primarily through our subsidiaries and affiliated PRC
entities in China. As a result, our cash requirements and our ability to pay dividends principally depend upon dividends and other distributions from our subsidiaries, which in turn are derived principally from earnings generated at our affiliated
PRC entities. Specifically, The9 Computer (one of our subsidiaries in China) obtains funds from the PRC entities in the form of payments under the exclusive technical service agreements, pursuant to which The9 Computer is entitled to determine the
amount of payment.

 The Company acknowledges that the PRC government imposes controls on the convertibility of
the RMB into foreign currencies, and in certain cases, the remittance of currency out of China. However, under existing PRC foreign exchange regulations, payments of current account items, including profit distributions and trade and service-related
foreign exchange transactions, can be made in foreign currencies without prior approval from PRC State Administration of Foreign Exchange, or SAFE, by complying with certain procedural requirements. Therefore, the Company is able to pay dividends in
foreign currencies without prior approval from SAFE. Approval from or registration with appropriate government authorities is required where RMB is to be converted into foreign currency and remitted out of China to pay capital expenses such as the
repayment of loans denominated in foreign currencies.

 Furthermore, if our subsidiaries or any newly formed
subsidiaries incur debt on their own behalf, the agreements governing their debt may restrict their ability to pay dividends to us. See “Item 3. Key Information — D. Risk Factors — Risks Related to Doing Business in China —
Restrictions on currency exchange in China limit our ability to utilize our revenues effectively, make dividend payments and meet our foreign currency denominated obligations.”

5. We note your disclosures in Note 26 regarding the statutory reserve requirements for certain of your PRC subsidiaries and
consolidated affiliated entities. Please tell us your consideration to include a discussion of these reserve requirements here and their potential impact on the company’s liquidity. Please include in your revised disclosures the amount of
unrestricted net assets that would be available to the parent holding company if it wer