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November 17, 2022
Lei Xu
Chief Executive Officer
JD.com, Inc.
20th Floor, Building A, No. 18 Kechuang 11 Street
Yizhuang Economic and Technological Development Zone
Daxing District, Beijing 101111
People’s Republic of China
Re:JD.com, Inc.
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 28, 2022
Correspondence filed November 9, 2022
File No. 1-36450
Dear Lei Xu:
            We have reviewed your November 9, 2022 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
October 26, 2022 letter.
Correspondence filed November 9, 2022
Introduction, page 2
1.We note your response to our prior comment 1. Please further revise your disclosure to
clarify whether regulatory actions related to data security or anti-monopoly concerns in
Hong Kong may impact your ability to conduct your business, accept foreign investment
in the future or continue to list on a U.S. and/or foreign exchange. We note your proposed
revisions are limited to stating that "[a]s of the date of the annual report" these regulatory
actions do not have a material impact on your company.

 FirstName LastNameLei Xu
 Comapany NameJD.com, Inc.
 November 17, 2022 Page 2
 FirstName LastName
Lei Xu
JD.com, Inc.
November 17, 2022
Page 2
Item 3. Key Information
Cash and Assets Through Our Organization, page 3
2.We note your response to prior comment 2 and reissue in part. Please revise your
summary risk factors and risk factors sections to disclose the status of restrictions or
limitations in Hong Kong on cash transfers in, or out of, your Hong Kong entities.
Specifically, we note that, while you state that currently there are not restrictions or
limitations in place, if certain PRC restrictions or limitations would become applicable,
your Hong Kong entities may not be able to fund operations or use funds for other use
outside of Hong Kong.
Risk Factors
Our business is subject to complex and evolving Chinese and international laws and
regulations..., page 18
3.We note your response to prior comment 3 and reissue in part. Please revise your relevant
risk factor to briefly disclose the specific relevant laws and/or regulations governing
oversight of data security in Hong Kong and how they apply to your business operations.
In this regard, we note that this risk factor specifically refers to the GDPR in the context
Europe and its applicability to the handling of personal data and individual privacy rights
in relation to stored data.
            You may contact Tatanisha Meadows at 202-551-3322 or Linda Cvrkel at 202-551-
3813 if you have questions regarding comments on the financial statements and related
matters.  Please contact Kate Beukenkamp at 202-551-3861 or Mara Ransom at 202-551-
3264 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Sandy Xu, Chief Financial Officer