SecProbe.io

November 26, 2018
Donghao Yang
Chief Financial Officer
Vipshop Holdings Ltd
No. 20 Hauhai Street
Liwan District, Guangzhou 510370
The People's Republic of China
Re:Vipshop Holdings Ltd
Form 20-F for Fiscal Year Ended December 31, 2017
Filed April 19, 2018
File No. 1-35454
Dear Mr. Yang:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2017
Consolidated Statements of Income and Comprehensive Income, page F-7
1.Please tell us your consideration of disclosing the changes in accumulated balances of
each component of other comprehensive loss included in accumulated other
comprehensive loss recorded in equity.  Refer to ASC 220-10-45-14A.  Also, tell us your
consideration of disclosing the income tax effects attributable to unrealized gains (losses)
on available for sale investments and reclassification adjustments included in
comprehensive income and including a sub-total for the components that make up other
comprehensive (loss) gain.  Refer to ASC 220-10-45-12 and 220-10-45-1B.b.
Note 4 Accounts Receivable, net, page F-42
2.Please tell us your consideration of providing the disclosures in ASC 310-10-50-1 through
34 related to your financing receivables.  Additionally, please tell us why your provision

 FirstName LastNameDonghao Yang
 Comapany NameVipshop Holdings Ltd
 November 26, 2018 Page 2
 FirstName LastName
Donghao Yang
Vipshop Holdings Ltd
November 26, 2018
Page 2
for doubtful accounts during each of the years in the table on page F-42 do not agree to
the provision for allowance for doubtful accounts presented in the operating activities
section of the statements of cash flows.
Note 11. Other Investments, page F-47
3.Please tell is your consideration of the disclosures in ASC 320-10-50-6a.
Available-for-Sale Investments, page F-47
4.Please tell us your consideration of the disclosures in ASC 320-10-50-9b.
Note 17 Short term loans and securitizations, page F-50
5.The disclosures related to short-term loans do not reconcile to the total recorded in the
balance sheet.  Please advise or revise.
Note 28. Segment information, page F-67
6.Please tell us your consideration of disclosing the amount of investments in equity method
investees and total expenditures for additions to long-lived assets by segment.  Refer to
ASC 280-10-50-25a and b.  Also, tell us if equity in the net income of investees accounted
for by the equity method, interest income and interest expense by segment is provided to
your chief operating decision maker.  If so, tell us your consideration of the disclosures in
ASC 280-10-50-22.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Tony Watson, Staff Accountant, at (202) 551-3318 or William
H.Thompson, Accounting Branch Chief, at (202) 551-3344 with any questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products