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CORRESP
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CORRESP

 Bilibili Inc.

Building 3, Guozheng Center, No. 485 Zhengli Road

Yangpu District, Shanghai, 200433

People’s Republic of China

September 26, 2023

 VIA EDGAR

Ms. Laura Veator

 Mr. Stephen Krikorian

Mr. Austin Pattan

 Mr. Andrew Mew

Division of Corporation Finance

 Office of Technology

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Bilibili Inc. (the “Company”)

Form 20-F for the Fiscal Year Ended December 31, 2022

Filed April 27, 2023 (File No. 001-38429)

Dear Ms. Veator, Mr. Krikorian, Mr. Pattan and Mr. Mew,

This letter sets forth the Company’s responses to the comments contained in the letter dated August 29, 2023 from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2022 filed with the
Commission on April 27, 2023 (the “2022 Form 20-F”). The Staff’s comments are repeated below in bold and are followed by the Company’s responses thereto. All capitalized terms used but
not defined in this letter shall have the meaning ascribed to such terms in the 2022 Form 20-F.

 Form 20-F for the Fiscal Year Ended December 31, 2022

 Item 3. Key Information, page 5

1.
 Please provide a detailed legal analysis regarding whether the company and each of its subsidiaries meet the
definition of an “investment company” under Section 3(a)(1)(A) of the 1940 Act. In your response, please address, in detail, each of the factors outlined in Tonapah Mining Company of Nevada, 26 SEC 426 (1947) and
provide legal and factual support for your analysis of each such factor.

 Section 3(a)(1)(A) of the Investment
Company Act defines the term “investment company” to include any issuer which “is or holds itself out as being engaged primarily, or proposes to engage primarily, in the business of investing, reinvesting, or trading in
securities” (emphasis added). The determination of an issuer’s primary business engagement requires a fact-specific inquiry. Over the years, the SEC and the courts have developed a number of criteria to be used in determining whether a
company is engaged primarily in a non-investment business. The criteria applicable to nearly every situation are: (i) the company’s historical development; (ii) its public representations of
policy; (iii) the activities of its officers and directors; (iv) the sources of its present income; and (v) the nature of its present assets (the “Tonopah
Factors”).1

1
 Tonopah Mining Co. of Nev., 26 S.E.C. 426, 427 (1947); Certain Prima Facie Inv. Cos., Investment Company
Act Release No. IC-10937, 18 S.E.C. Docket 948 (1979).

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 26, 2023

 Page 2

 Although the SEC has not indicated how much emphasis should be placed on any particular
criterion, it has indicated that, in general, more significance should be placed on the character of a company’s assets (as evidenced by the relative percentage of a company’s assets invested in operating businesses (“operating
assets”) versus investment instruments (“investment assets”)), and the sources of the company’s present income (as evidenced by the relative percentage of the company’s income derived from operating assets versus investment
assets).2 However, other considerations may apply in the application of the foregoing factors, for example, a company’s investment holdings may be based on such company’s need for cash
for operations or acquisitions or other needs and a desire to preserve the value of such cash. In general, SEC and court decisions indicate that if an applicant has demonstrated significant activity in a
non-investment business, a need for available capital, and the absence of public representations that it is in the investment business, no registration is required.

Because the Company does not hold itself out to be an investment company, the relevant consideration is whether the Company is
“primarily” engaged in the investment business. The following sections analyze the application of the five Tonopah Factors to the Company’s business.

Historical Development

The Company first launched its website in June 2009, and the Company commenced commercial operations in 2011 as an online video sharing
platform. The Company established Shanghai Hode Information Technology Co., Ltd. (“Hode Information Technology”) to expand its operations in May 2013. In December 2013, Bilibili Inc. was incorporated in the Cayman Islands to serve as the
Company group’s ultimate holding company. In February 2014, the Company established Hode HK Limited (“Hode HK”), a wholly-owned Hong Kong subsidiary, and in September 2014, Hode HK established a wholly-owned PRC subsidiary, Hode
Shanghai Limited (“Hode Shanghai”). Hode Shanghai then entered into a series of contractual arrangements with each of its variable interest entities (“VIEs”), Hode Information Technology and Shanghai Kuanyu Digital Technology
Co., Ltd. (“Shanghai Kuanyu”), and their respective shareholders. Chaodian HK Limited (“Chaodian HK”), a wholly-owned subsidiary of Bilibili Inc., was established in 2019. Chaodian HK’s wholly-owned subsidiary, Chaodian
Shanghai Technology Co., Ltd. (“Chaodian Technology”), subsequently entered into a series of contractual arrangements with Shanghai Chaodian Culture Communication Co., Ltd. (“Chaodian Culture”) and its shareholders pursuant to
which Chaodian Technology became the sole beneficiary of, and gained control of, Chaodian Culture. American Depositary Shares (“ADS”) representing the Company’s Class Z ordinary shares commenced trading on the Nasdaq Global
Select Market under the symbol “BILI” on March 28, 2018.

2
 Investment Company Act Release No. IC-10937, supra note 1;
Tonopah, 26 S.E.C. at 427. But see SEC v. National Presto Industries, Inc. 486 F.D.A. 305 (7th Cir. 2007), in which the Court rejected the assertion that the composition of a company’s assets is the most important of these
five considerations; rather, what is most important is whether the company’s “portfolio and activities [will] lead investors to treat a firm as an investment vehicle or as an operating enterprise.”

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 26, 2023

 Page 3

 The Company is a holding company that currently conducts its business in China mainly through
(i) Hode HK and its subsidiaries, Shanghai Bilibili Technology Co., Ltd. (“Bilibili Technology”) and Hode Shanghai, and the VIEs, Shanghai Kuanyu and Hode Information Technology, and its subsidiaries and (ii) Chaodian HK and its
subsidiary, Chaodian Technology, and its VIE, Chaodian Culture. Through its subsidiaries, VIEs and their subsidiaries (“Consolidated Operating Entities”), the Company offers a leading online video platform as well as mobile games and
anime, comic and audio platforms.

 The Company and its Consolidated Operating Entities maintain significant intellectual property with
respect to its primary business of providing video and other media content platforms. For example, as of December 31, 2022, the Company and its Consolidated Operating Entities have registered approximately 985 patents, 1,847 copyrights, and
8,154 trademarks and is in the process to register an additional approximately 1,863 patents and 1,171 trademarks. The Company and its Consolidated Operating Entities have approximately 350 registered domain names as of December 31, 2022.

The Company’s and its Consolidated Operating Entities’ devotion to their business of providing video and other media content
platforms is demonstrated by the fact that substantially all of their revenue is derived from their offerings of value added services (the “VAS”) such as premium subscriptions, live broadcasting, anime and comics and audio drama content;
mobile games; advertising and e-commerce through its Consolidated Operating Entities, and not from investment securities. Similarly, substantially all of the expenses the Company and its Consolidated Operating
Entities incur in the ordinary course of their business are incurred in connection with the operation of its online video, media and e-commerce platforms, and not in connection with investment securities. For
the year ended December 31, 2022, the Company and its Consolidated Operating Entities neither derived significant revenue nor incurred significant expenses in connection with investment securities.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 26, 2023

 Page 4

 Public Representations

The Company has never held itself or any of its Consolidated Operating Entities out to the public (or to investors) as an investment company.
The Company and its Consolidated Operating Entities were organized for the purpose of, and since the Company became a public reporting company in the United States in 2018 have always stated that their business purpose is, providing online video,
game and other media and e-commerce platforms through subsidiaries and relevant Consolidated Operating Entities . The Company believes that the price of the Company’s ADSs may be affected by a number of
factors, including, but not limited to, the following: (i) the Company’s results of operations and financial conditions; (ii) the Company’s strategies and future business development; (iii) the Company’s ability to
retain and increase the number of users, members and advertising customers; provide quality content, products and services; and expand its product and service offerings; (iv) competition in the online entertainment industry; (v) the
Company’s ability to maintain its culture and brand image within its addressable user communities; (vi) the Company’s ability to manage its costs and expenses; (vii) PRC governmental policies and regulations relating to the
online entertainment industry; (viii)general economic and business conditions globally and in China; and (ix) assumptions underlying or related to any of the foregoing. Further information regarding these and other factors that could affect the
price of the Company’s ADSs is disclosed in the 2022 Form 20-F. The Company does not believe the price of the Company’s ADSs will move in response to changes in its investment income or the
composition of its investment holdings. Moreover, neither the Company nor any of its Consolidated Operating Entities devote any attention to nor has the Company disclosed its or its Consolidated Operating Entities’ financial management or
securities activities on its website or in its public documents except as required by law.

 Directors, Officers and Employees

The business activities of the Company’s and its Consolidated Operating Entities’ directors, officers and employees historically have
been devoted almost exclusively to its business of providing online video, game and other media and e-commerce platforms in China, including the governance and operational activities involved in supporting
that business. As of December 31, 2022, the Company and its Consolidated Operating Entities had approximately 11,092 employees, only 5 of whom were actively involved in managing the Company’s investments. It is estimated that none of these
persons devote more than 50% of his or her time to managing the Company’s investments. The other 11,087 officers and employees, who represented more than 99% of the Company’s total officers and employees as of December 31, 2022,
devote substantially all of their time and business efforts at the Company to the Company’s online media and e-commerce businesses and to functions that support those businesses and not to managing
investments owned by the Company. These employees were actively engaged in growing the Company’s business and were utilizing the Company’s cash to fund the Company’s business operations.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 26, 2023

 Page 5

 Sources of Income

The Company’s filings indicate that the results of the Company and its Consolidated Operating Entities are driven by their position as a
leading video community for young generations in China, with a rich offering of content, including video services, mobile games and VAS. Substantially all of the Company’s and its Consolidated Operating Entities’ revenue is derived from
their offerings of VAS, advertising, mobile games, and intellectual property (“IP”) and other derivative products through its e-commerce platform. Users of the Company’s and its Consolidated
Operating Entities’ platforms are charged for certain features and functions, such as live broadcasting, premium membership subscriptions allowing access to premium content, comics and audio content. The Company and its Consolidated Operating
Entities also generate revenue from advertising on their platforms. The Company and its Consolidated Operating Entities also generate considerable revenue from the sale of in-game virtual items in its
exclusively licensed and jointly published mobile games. Additionally, the Company and its Consolidated Operating Entities generate revenue from the sales of IP and derivative products through its e-commerce
platform.

 More than 99% of the Company’s and each Consolidated Operating Entities’ total revenue for the twelve-month period
ended December 31, 2022 was derived from their mobile games, services offered through their video and digital media platforms, advertising on their platforms, sublicensing licensed content and e-commerce
sales, and not from investment securities. Similarly, more than 99% of the Company’s and each Consolidated Operating Entities’ expenses for the twelve-month period ended December 31, 2022 were incurred in connection with the provision
of products through the Company’s e-commerce platform and the provision of services and virtual items through their online media platforms and mobile games, including through revenue sharing arrangements
with mobile game developers, distribution payment channel partners, hosts and content creators; content licensing and production costs; bandwidth costs and employee salaries, benefits and share-based compensation, and not in connection with
investment securities.

 Nature of Present Assets

As described in more detail in response to comment 2 below, while investment securities may represent greater than 40% of the adjusted total
assets of certain of the Company’s subsidiaries when calculated in accordance with the unique method required by Section 3(a)(1)(C) of the 1940 Act, investment securities represent approximately 29.48% of the Company’s adjusted total
assets as of June 30, 2023 when calculated in accordance with Section 3(a)(1)(C) of the 1940 Act. Because this is less than 45% of the Company’s adjusted total assets, this factor indicates that the Company is not engaged in an
investment company business.3

3
 See Investment Company Act Release No. IC-10937, supra note 1
(“As a general rule, however, if a company has no more than 45 percent of its assets invested in—and derives no more than 45 percent of its income from—investment securities, it is primarily engaged in a business other than
being an investment company. Accordingly, it would not appear necessary or appropriate in the public interest for the Commission to regulate such a company under the [Investment Company] Act.”).

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 26, 2023

 Page 6

 Conclusion

Based on the foregoing, neither the Company nor any of its Consolidated Operating Entities is engaged in an investment company business, but
rather is primarily engaged in the business of offering online media content, including video services, mobile games and VAS.

2.
 Please provide a legal analysis of whether the company and each of its subsidiaries meets the definition