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Correspondence

 [Letterhead of The9 Limited]

February 6, 2013

 VIA EDGAR
AND FAX

 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 January 23, 2013 from the Staff of
the Commission (the “Staff”) regarding our annual report on Form 20-F for the year ended December 31, 2011 (the “2011 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 5. Operating and Financial Review and Prospects

 Results of
Operations, page 52

1.
Aside from the information provided in your response to prior comment 3, tell us whether there are any other operational statistics and usage patterns monitored
by the company which affect your results of operations. For example, it would seem that disclosing the average number of users would be useful information to investors as it could add context to the percentage of your total users that pay to play
and the potential market for future paying players. 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 further enhance its disclosure by including the information related to the average
number of quarterly active users, average number of quarterly paying users and average quarterly revenue per paying user. Specifically, the Company proposes to include disclosures substantially in the form as shown below in its annual report on Form
20-F for the fiscal year ended December 31, 2012 to replace the disclosure included 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 — Online Game Services” in its annual report on the 2011 Form 20-F. To facilitate the Staff’s review process, updated portion of the disclosure is shown in underline.

 1

 Our revenues from online game services increased by 2.4%, from RMB106.5 million in 2010 to RMB109.0 million
(US$17.3 million) in 2011. The increase was primarily due to an increase in revenues from TV games, partially offset by a decrease in revenues from PC games.

 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 the number of average quarterly paying users 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 decrease in average quarterly paying users was in line with the decrease in our number of average quarterly active
users from 2,527,451 in 2010 to 1,989,833 in 2011. Such decreases were mainly associated with our commercialized games launched in or before 2010 which have reached the mature stage of their life cycles and are experiencing a decreasing trend in
popularity, although the decrease was slightly offset by a scalable PC game we launched in 2011. We expect the revenue from the mature games to continue to decrease, and if we are unable to introduce more popular new games on a timely manner, this
decreasing trend will have a material and adverse effect on our financial condition, results of operations and cash flows.

 The number
of quarterly active users refers to the number of users who log into our games at least once during a quarter. The number of average quarterly active users is the average of quarterly active users for each of the four quarters during a year.
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 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 the number of average quarterly paying users from 62,013 in 2010 to 124,536 in 2011 and an increase in the average quarterly revenue per paying user from RMB13 in 2010 to
RMB19 in 2011, all due to continuous expansion in our TV game platform and more quality games launched in 2011. Unlike PC games, our TV games are operated through telecom carriers and we do not maintain information relating to active user pursuant
to our cooperation agreements with the telecom carriers.

 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.

 2

2.
The revised disclosures provided in response to prior comment 3 indicate that your PC games revenue decreased due to decreases in your average quarterly paying
users and average quarterly revenue per paying user. Please revise further to explain the reasons for the decreases in such quarterly averages.

 The Staff’s comments are duly noted and the Company has proposed to revise its future filings to provide disclosure regarding the reasons for the decreases in average quarterly paying users and
average quarterly revenue per paying user. Company respectively refers the Staff to our response to comment 1 for our proposed disclosure.

Item 15. Controls and Procedures

 Disclosure Controls and Procedures, page 83

3.
Please revise your December 31, 2011 Form 20-F to include the revisions proposed in your response to our prior comment 6 as it relates to management’s
conclusions regarding the effectiveness of the company’s disclosure controls and procedures.

 The Staff’s
comments are duly noted. The Company will file an amendment to its annual report on the 2011 Form 20-F to include management’s conclusions regarding the effectiveness of the company’s disclosure controls and procedures.

Item 18. Financial Statements

Note 2. Principal Accounting Policies

 Revenue Recognition, page F-20

4.
Please describe further, for us, (a) the in-game features that are immediately consumed, (b) the premium features with stated expiration and
(c) the in-game perpetual features. Please provide specific examples for each of these virtual goods and tell us how you determined which in-game premium features are considered to be consumed immediately versus those that are consumed over the
estimated average life of game play.

 In response to the Staff’s comments, the Company has set out below certain
examples for each of the three types of game items that it sells to the game users:

 (a) In-game features that are immediately consumed:

 “Healing Potion” is an in-game item commonly purchased and used by players in role playing games. By consuming it, it increases the
Health Point, or HP, of the player for a designated amount for one time. When the player is attacked by an enemy or monster in the game, the HP of the player will drop accordingly and the player will be killed if the HP decreases to zero. As such,
the player typically needs to purchase and consume the Healing Potion to replenish the HP to avoid being killed.

 3

 (b) Premium features with stated expiration:

 In our games, certain in-game items have a stated expiration period. For example, when a player uses a “Magic Stick”, a special skill for fighting which causes greater damage to enemies or
monsters is made available to the player. Such functionality of the “Magic Stick” to provide the special skill is only valid for thirty days from the date of purchase. After the thirty-day period, the player cannot use the “Magic
Stick” purchased anymore and the player needs to purchase another “Magic Stick” for the special skill for future fights.

 (c)
In-game perpetual features:

 A typical example for an in-game item with perpetual features is an avatar, which players may use to customize
their characters. The avatar has no time limit. Once the player purchase and apply the avatar, the player can always see its character with that specific avatar when the player logs in the game.

The Company evaluates the terms related to its in-game features to determine the proper category which such items fit into (i.e., immediately consumable,
with stated period of duration or durable, and perpetual) and apply the revenue model accordingly. Immediately consumable items are in-game features that are immediately consumed by a specific action, such as the Healing Potion mentioned above. In
these instances, the Company will recognize revenue once the item is consumed because its consumption is completed immediately upon the election to utilize the feature by the game player. For premium features with stated expiration, like the Magic
Stick mentioned above, there is an explicit period during which the Company provides access or use of the feature purchased by the game player. Accordingly, the Company recognizes the related revenue ratably over the feature’s stated period of
use, such as thirty days in the example of the “Magic Stick.” For the in-game perpetual features, as discussed in the Company’s previous response, the Company applies a user-based revenue model, pursuant to which the period of
delivery is considered to be the estimated average life of game play for paying players. Therefore, revenue from the avatar is recognized over the average life of game play determined for the specific game, starting from the time when the player
applies the avatar.

 Note 4. Variable Interest Entities, page F-28

5.
The proposed disclosure provided in response to our prior comment 9, states in part, that the Exclusive Technical Service Agreements have an initial term of 20
years, with the earliest expiration date being December 31, 2029. However, as per our review of Exhibit 10.4 (as filed with your November 26, 2004 Form F-1) and Exhibit 4.32 (as filed with your December 31, 2010 Form 20-F), it appears
that the 20-year term only applies to the Huopu Cloud agreement. Please revise the proposed disclosure to properly reflect the terms of the Exclusive Technical Service Agreement between for both of your VIE arrangements. To the extent that the terms
of the Shanghai IT Agreement were changed, please file a copy of the amended Agreement as an Exhibit. We refer you to the Instructions as to Exhibits of Form 20-F.

 4

 The Company respectfully advises the Staff that the terms of the Exclusive Technical Service Agreement dated
January 1, 2004 between The9 Computer and Shanghai IT (filed as Exhibit 10.4 with the Company’s registration statement on Form F-1 dated November 26, 2004 ) (“Shanghai IT Agreement”) was amended on December 15, 2010.
The amended Shanghai IT Agreement provides that it takes effect on January 1, 2010 retrospectively and shall remain in effect for 20 years (with the earliest expiration date being December 31, 2029). As a result, the 20-year term is
applicable to both the Huopu Cloud Agreement (filed as Exhibit 4.32 with the Company’s annual report on Form 20-F dated December 31, 2010), and the amended Shanghai IT Agreement.

 In response to the Staff’s comment, the Company will file a copy of the amended Shanghai IT Agreement as an exhibit to its amendment to the annual report on 2011 Form 20-F.

6.
We note your response to prior comment 10 where you state “…if the Company, its PRC subsidiaries and VIEs are found to be in violation of any existing
or future PRC laws or regulations, or fail to obtain or maintain any of the required permits or approvals, the relevant PRC regulatory authorities would have broad discretion in dealing with such violations, including requiring the Company to
undergo a costly and disruptive restructuring such as forcing the Company to transfer its equity interest in the PRC subsidiaries to a domestic entity or invalidating the VIE agreements. If the PRC government authorities impose penalties which cause
the Company to lose its rights to direct the activities of and receive economic benefits from the VIEs, the Company may lose the ability to consolidate and reflect in its financial statements the financial condition, and results of operation of the
VIEs, which are disclosed in F-28, which would likely be a material adverse event for the Company.” Please revise to include this information in your Note 4 disclosures in future filings.

The Staff’s comments are duly noted and the Company plans to include such disclosure in its annual report on Form 20-F for the fiscal year ended
December 31, 2012.

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

7.
You state in your response to our prior comment 13 that the unrelated Chinese online game company which took over the WoW license in the PRC publicly committed to
WoW players that they could use any unconsumed WoW point cards sold by The9 and continue to play WoW on their company’s platform. Tell us how you account for WoW points used by your cardholders on the other company’s platform. Tell us how
you are able to determine when the points are used in game play and tell us the amount of revenues recognized from such usage for each period since the loss of the WoW license. If you have not recognized any revenues for previously activated points
consumed since the loss of the WoW license or to the extent that you do not intend on recognizing any such revenues, please explain why.

 5

 The Company respectively advises the Staff that it believes that the offer to honor the activated and
unconsumed game points by the unrelated Chinese online game company which took over the WOW license was a marketing technique adopted by such company to attract and maintain existing players of the game. This offer was made without the participation
of the Company and the Company does not believe that the offer relieved the Company of its legal obligations to WoW players with respect to the unconsumed game point cards sold by the Company. Accordingly, the Company does not account for the
activated and unconsumed game points used on the platform of the unrelated Chinese game company based on such usage information as the offer to honor such game points does not affect the Company’s obligations the purchasers of such game points.

 As previously discussed in the Company’s response to the Staff’s comment 13, the Company determined, in consultation with its PRC
legal counsel, that at the time the Company lost the WoW license, it was no longer in a position to honor its commitments to game players who purchased point cards. The Company considered the guidance in ASC 405-20-40-1 which states, in part, as
follows:

 A debtor shall derecognize a liability if and only if it has been extinguished. A liability has been extinguished
if either of the following conditions is met:

 b. [The debtor is legally released from being the primary obligor under
the liability, either judicially or by the creditor.

 Accordingly, the Company identified two types of refund obligations (or
liabilities), depending on whether the game point cards were activated or unactivated.

 For unactivated WoW game point cards, the Company made
a public announcement with respect to its plans to make refunds. As a result of such actions, the Company believes that, pursuant to the Article 135 of the General Principles of the Civil Law of the PRC (1987) and Article 6 of Regulations about
Limitation of Action of PRC 2008, the statute of li