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Correspondence

 Bilibili Inc.

Building 3, Guozheng Center, No. 485 Zhengli Road

Yangpu District, Shanghai, 200433

People’s Republic of China

 November 13, 2023

VIA EDGAR

 Ms. Laura Veator

Mr. Stephen Krikorian

 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 and Mr. Krikorian,

This letter sets forth the Company’s responses to the comments contained in the letter dated October 17, 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. Where financial information is required, the Company has provided such information up to and including the
quarter ended June 30, 2023, which is the most recently available fiscal quarter.

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

 Item 3. Key Information, page 5

1.
 Please supplement the Company’s discussion of the “Officers and Directors” factor under
Tonopah (as set forth in the Company’s response to comment 1) to describe the titles or roles of the five persons who are actively involved in managing the Company’s investments.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

November 13, 2023

  Page
 2

 The employees of the Company who are actively involved in managing the Company’s
investments are as follows:

 Number of
Employee(s)

 Title

 Job Responsibilities

1

Senior Supervisor

Developing strategies regarding the Company’s cash management, equity investment, and other financial activities. Overseeing the management of cash flow, financial risks, investment and banking relationships.

2

Senior Associate

Handling the Company’s banking relationships, equity investment and other corporate treasury matters; coaching the work of the two Associates who provide assistance.

1

Associate

Preparing analysis and proposals for various uses of corporate treasury funds, improving the efficiency of corporate treasury fund usage, managing accounts payable and accounts receivable, and assisting with other corporate treasury
matters

1

Associate

Handling intra-group corporate treasury fund movement between the Company and its Consolidated Operating Entities based on business needs, apply for various types of credit from banks and other financial institutions, coordinate
with other departments in relation to auditing, project settlement, and other work streams, and assisting with other corporate treasury matters

2.
 We note that the Company’s discussion of the “Sources of Income” factor under
Tonopah states, “[m]ore 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 [and certain
other sales and services] and not from investment securities.” In addition, the discussion states, “more than 99% of the Company’s and each Consolidated Operating Entities’ expenses for the twelve-month period ended
December 31, 2022 were incurred [ . . . ] not in connection with investment securities.”

•

 Please supplement this response with figures as of September 30, 2023 or the most recently available
fiscal quarter end.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

November 13, 2023

  Page
 3

•

 The Company’s discussion was not sufficiently detailed to allow the staff to assess the Company’s
position. Accordingly, please supplement this response to specifically provide the aggregate dollar amount and percentage attributable to each source of income (and expense) identified in the response (e.g., mobile games, services offered through
video and digital media platforms, provision of products through the Company’s e-commerce platform, etc.). Please also discuss how 99% of the Company’s total revenue and 99% of the Company’s
expenses was not derived from, or incurred in connection with, investment securities when, as noted in the Company’s discussion of the “Sources of Income” factor under Tonopah, the Company’s 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 Investment Company Act of 1940 (the “Act”) and certain other
Company Group (as defined in the Company’s response to comment 2) issuers have investment securities representing high percentages of adjusted total assets.

The Company respectfully submits that

•

 For the twelve months ended December 31, 2022 and the six months ended June 30, 2023, the Company and
its Consolidated Operating Entities (for purposes of this response, collectively, the “Company”) had total income of RMB23,656.8 million and RMB11,096.2 million, respectively, with 99.5% and 98.1% of the total income derived from
sources unrelated to investment securities, respectively.

•

 For the twelve months ended December 31, 2022 and the six months ended June 30, 2023, the Company had
total expenses of 31,164.4 million and RMB13,273.9 million, respectively, with 99.8% and 100.0% of the total expenses incurred from sources unrelated to investment securities, respectively.

Further to the above, the Company is submitting a breakdown and detailed discussions with respect to its source of income and expenses in
Appendix A of the supplemental response, which the Company is submitting under separate cover and on a confidential basis.

 While the
Company’s investment securities represented approximately 29.48% of the Company’s adjusted total assets as of June 30, 2023 when calculated in accordance with the unique method required by Section 3(a)(1)(C) of the Act, and
certain other Company Group issuers held investment securities representing high percentages of their adjusted total assets, the Company’s and the Company Group’s investment securities did not produce a significant percentage of such
entities’ income during the period, particularly in light of the current interest rate and market environments and in comparison to the Company’s operating businesses.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

November 13, 2023

  Page
 4

3.
 The Company’s response to comment one, under the heading “Nature of Present Assets,” refers
to its response to comment 2. However, neither such response appears to provide information about the nature of the Company’s present assets on a consolidated basis. Accordingly, please describe the nature of the Company’s present assets
on a consolidated basis as of the most recent fiscal quarter end (September 30, 2023 (if available)). Please also provide sufficient detail on the manner in which this calculation is made, including a discussion of any substantive determinations
and/or characterizations of assets that are material to your calculation.

 The Company respectfully notes that the
40% Test under Section 3(a)(1)(C) of the Act is to be conducted on an unconsolidated basis. As detailed in the Company’s response to comment 2 of the initial comment letter, investment securities represent approximately 29.48% of the
Company’s adjusted total assets when calculated on an unconsolidated basis, thus the Company is not an investment company as defined in Section 3(a)(1)(C).

Additionally, the Company is submitting the requested information with respect to the Company’s total present assets on a consolidated
basis in Appendix A of the supplemental response, which the Company is submitting under separate cover and on a confidential basis for the Staff’s information.

The Company further submits that its historical development, its public representations of policy, the activities of its officers and
directors, the sources of its present income and the nature of its present assets, as discussed in the Company’s response to comment 1 of the initial comment letter and supplemented in Appendix A hereto, demonstrate that the Company is engaged
primarily in a non-investment business and thus is not an investment company as defined in Section 3(a)(1)(A) of the Act.

4.
 The staff notes the Company’s discussion of the various categories of assets of the Company and its
subsidiaries in its response to comment 3. However, because these responses are provided for multiple entities, they are often qualified (“generally” or “consist primarily”). Moreover, the labels of the assets in the response do
not match the labels used in Appendix A. Please provide an updated response, as of the most recent fiscal quarter end (September 30, 2023 (if available)), that identifies each constituent part of the numerator(s) and denominator(s) for each entity,
including a discussion of any substantive determinations and/or characterizations of assets that are material to your calculations with respect to such entity. For example, when referring to an entity’s intercompany receivables or investments
in majority-owned subsidiaries that are not investment companies, please ensure that your response clearly describes the nature of such assets, including their constituent parts, with respect to that specific entity and the basis for the
Company’s treatment of such assets.

 The Company has updated the Investment Company Act Calculations to reflect
the requested information. The Investment Company Act Calculations are set forth in Appendix A of the supplemental response, which the Company is submitting under separate cover and on a confidential, supplemental basis.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

November 13, 2023

  Page
 5

5.
 In providing the information referenced above on an entity-by-entity basis, please also be sure to address the questions below for the following asset categories identified in its response to comment 3:

•

 Amounts due from Group companies.

○

 We note that the Company’s response addresses certain intercompany loans represented by notes or loan
agreements, or on which interest is charged. Please discuss whether the Company Group assets consist of receivables due or owing in connection with intercompany loans which are not represented by notes or loan agreements, or on
which interest is not charged. Discuss also whether, and in which asset category, these assets are reflected, and how the Company treats these assets for purposes of Section 3(a)(1)(C) of the Act.

•

 Time deposits.

○

 Discuss whether any entity in the Company Group has deposits with maturities of less than 3 months and the
Company’s proposed treatment of these assets for purposes of Section 3(a)(1)(C) of the Act.

•

 Restricted cash.

○

 Discuss the amount of restricted cash subject to restricted withdrawal periods, including whether any such
cash is invested in securities, certificates of deposits, or any other assets. Please describe the legal rationale for the Company’s position that the restricted cash is not an investment security and its treatment for purposes of
Section 3(a)(1)(C) of the Act.

 The Company has included the requested information with respect
to each asset category under “Investment Company Act Calculations” in Appendix A of the supplemental response, which the Company is submitting under separate cover and on a confidential, supplemental basis.

For the avoidance of doubt, the Company confirms that the Company Group assets do not consist of receivables due or owing in connection with
intercompany loans which are not represented by notes or loan agreements (whether or not interest is charged). As reflected in the Company’s response to comment 4 above, all intercompany loans are represented by notes or loan agreements,
whether or not interest is charged, and all such intercompany loans were treated as investment securities for purposes of Section 3(a)(1)(C) of the Act.

The Company confirms that no entity in the Company Group has time deposits with original maturities of less than 3 months, and all of the
Company Group’s time deposits were treated as investment securities for purposes of Section 3(a)(1)(C) of the Act.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

November 13, 2023

  Page
 6

 The Company further confirms that only one entity in the Company Group, Shanghai Kuanyu
Digital Technology Co., Ltd., holds restricted cash as of June 30, 2023. RMB167.8 million of such restricted cash is subject to restricted withdrawal periods, and none of such cash is invested in securities, certificates of deposits or any
other assets. The Company treats such cash as a cash item for purposes of Section 3(a)(1)(C) because the fact that such cash is subject to a restricted withdrawal period or appointed for a specific business purpose does not alter the nature of
the asset. Such cash is plainly not a “security” as defined in Section 2(a)(36) of the Act, and therefore cannot be an “investment security” as defined in Section 3(a)(2) of the Act.

6.
 Please supplementally clarify how the wholly foreign-owned enterprise (“WFOE”) identified in
Appendix A treats each applicable variable interest entity (“VIE”) for purposes of Section 3(a)(1)(C) of the Act and explain the rationale for this treatment. More specifically, please discuss whether the Company treats the
WFOE’s relationship with the VIE as comprising the applicable WFOE’s total assets for purposes of Section 3(a)(1)(C) and, if so, how the Company is calculating the “value” of such amounts for purposes of
Section 2(a)(41) of the Act.

 The Company’s WFOEs identified in Appendix A are Hode Shanghai Limited
(“Hode Shanghai”) and Chaodian (Shanghai) Technology Co., Ltd. (“Chaodian Technology”). Hode Shanghai’s VIEs are Shanghai Kuanyu Digital Technology Co., Ltd. (“Shanghai Kuanyu”) and Shanghai Hode Information
Technology Co., Ltd. (“Hode Information Technology”); Chaodian Technology’s VIE is Shanghai Chaodian Culture Communication Co., Ltd. (“Chaodian Culture”).

Section 2(a)(43) of the Act defines “wholly-owned subsidiary” of a person as a company 95 per centum or more of the outstanding
voting securities of which are owned by such person, or by a company which, within the meaning of that paragraph, is a wholly-owned subsidiary of such person. Section 2(a)(42) of the Act defines “voting security” to mean, in pertinent
part, any security presently entitling the owner or holder thereof to vote for the election of directors of a company. This voting control need not be held by reason of the ownership of securities; rather it may arise under a voting agreement.1 It is clear, reading Sections 2(a)(42) and 2(a)(43) of the Act together, that a wholly-owned subsidiary is defined with reference to the ability to elect a majority of its board of directors.
Moreover, the courts and the Commission have taken the position that the possessor of an economic interest in an issuer, such that the holder of the economic interest has the power to exercise control over how the issuer is managed, is considered to
hold the equivalent of a voting security.2

1
 See Farley, Inc. (pub. avail. Apr. 15, 1988); Pengrowth Energy Trust (pub. avail. Jan. 27, 2000).
In Farley, Inc., the staff at the SEC stated that it would not recommend enforcement action if the company treated its subsidiary as a majority-owned subsidiary, even though it would own less than 50 percent of the voting power to elect
directors of the subsidiary, since it would have voting contr