SecProbe.io

Mail Stop 3561
August 21, 2015

Man San Law
Chief Executive Officer
500.com Limited
500.com Building
Shenxianling Sports Center
Longgang District, Shenzhen 518115
The People’s Republic of China

Re: 500.com Limited
 Form 20-F for Fiscal Year Ended December 31, 2014
Filed April 27, 2015
File No. 001 -36206

Dear Mr. Law :

We have reviewed your filing an d have the following comment .  In our comment , we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comment  applies to your facts and circumstances , please tell us why in your response.

After reviewing your response to this comment , we may have  additional comments.

General

1. In January 2015, the Ministry of Commerce of China released a discussion draft of
proposed leg islation for public comment, which appears to set out a plan for overhauling
Chinese foreign investment laws.  To the extent that the discussion draft may be material
to you or your operations please disclose the discussion draft, including how the propose d
changes may impact your operations.  In this regard, we note that neither the Risk Factors
section on page 6 nor the Regulation of Our Industry section on page 54 reference or
discuss this new proposed legislation.

Man San Law
500.com Limited
August 21, 2015
Page 2

 We urge all persons who are respon sible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicab le Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment , please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from  taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Donald E. Field  at (202) 551 -3680  or me at (202) 551 -3859  with any other
questions.

Sincerely,

 /s/ John Dana Brown

John Dana Brown
Attorney -Advisor
Office of Transportation and Leisure

cc: Chris Lin
 Simpson Thacher & Bartlett