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CORRESP

 FOIA Confidential Treatment

Requested Under 17 C.F.R. § 200.83

August 30, 2023

 VIA EDGAR

Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Technology

 100 F Street, N.E.

Washington, DC 20459

Attn:
 Stephen Krikorian, Accounting Branch Chief

Re:
 Sohu.com Limited

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

Filed March 30, 2023

File No. 001-38511

Dear Mr. Krikorian:

 We are submitting this
letter on behalf of Sohu.com Limited (the “Company” or “Sohu”) in response to the letter dated August 1, 2023 (the “Comment Letter”) from the Office of Technology of the Division of Corporation
Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) to Charles Zhang of the Company regarding the Form 20-F filed with the SEC on March 30,
2023 for the fiscal year ended December 31, 2022, File No. 001-38511 (the “2022 Form 20-F”). This letter reflects the Company’s
response to the Staff’s comments included in the Comment Letter.

 We respectfully request on behalf of the Company, pursuant to SEC
Rule 83, 17 C.F.R. §200.83, confidential treatment for certain portions of this letter that constitute commercially sensitive information. A redacted copy of this letter, omitting the confidential information, is being filed via EDGAR.

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

Risks Related to Our Ordinary Shares and ADSs, page 41

Staff Comment:

1
 We note your discussion of the Company’s potential status as an investment company under the Investment
Company Act of 1940 (the “1940 Act”), and in particular your disclosures regarding the Company’s investments in certain instruments that may be investment securities for purposes of Section 3(a)(2) of the 1940 Act. Please provide
a legal analysis of whether the Company meets the definition of “investment company” under Section 3(a) of the 1940 Act. Please include in your analysis all relevant calculations under Section 3(a)(1)(C) on an

 [***] Certain information in this letter
has been omitted and submitted separately to the Staff. Confidential treatment has been requested with respect to the omitted information.

CONFIDENTIAL TREATMENT REQUESTED BY SOHU.COM LIMITED

400 Atlantic Avenue, Boston, Massachusetts 02110-3333 (617) 482-1776 www.goulstonstorrs.com

 Securities and Exchange Commission

August 30, 2023

  Page
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unconsolidated basis, identifying each constituent part of the numerator(s) and denominator(s). Please also describe and discuss any substantive determinations and/or characterizations of
instruments, assets or asset classes that are material to your calculations. Additionally, if the Company meets the definition of “investment company” under Section 3(a) of the 1940 Act but relies or intends to rely on an exclusion
therefrom or a relevant exemption, please provide a legal analysis supporting such reliance.

 Response:

We advise the Staff that the Company does not meet the definition of “investment company” under Section 3(a)(1)(A) of the 1940
Act, because since its inception in 1996 the Company has never held itself out as, and does not propose to be, primarily engaged in “the business of investing, reinvesting, or trading in securities.” Section 3(a)(1)(B) of the 1940 Act
does not apply because the Company has never been engaged, and does not propose to engage, in the business of issuing face-amount certificates.

Regarding Section 3(a)(1)(C) of the 1940 Act, as a preliminary matter we note that some, but not all, commenters and courts have tended
to analyze the applicability of Section 3(a)(1)(C) to any particular issuer by focusing solely on the question of whether an issuer “owns or proposes to acquire investment securities,” and appear to read out of the language of the
provision the introductory words, “engaged in or proposes to engage in the business of investing, . . . in securities.” While we are aware that determining whether an issuer is engaged in a “business” of investing in securities
requires a partially subjective facts-and-circumstances analysis, and therefore we can understand why some courts or commenters might prefer to focus exclusively on the
bright-line 40% test, we do not agree that reading “engaged . . . in the business” out of the provision is correct as a matter of statutory interpretation.1 Nevertheless, solely for the
purpose of this discussion of the 40% test, and apart from the applicability of the Section 3(b)(1) exception discussed below, we will not address the question of whether or not the Company is engaged “in the business” of investing in
or holding securities for purposes of Section 3(a)(1)(C). We will also assume for this purpose, in accordance with positions that we are aware are generally (but not always) taken by the Staff, that none of the Company’s certificates of
deposit, regardless of their maturity dates, qualify as “cash items,” notwithstanding our belief that under a facts-and-circumstances analysis based on the
Company’s particular situation and focus, the Company’s certificates of deposit with terms of one year or less, and perhaps all of its certificates of deposit, could reasonably be considered to be cash items.2 Accordingly, in making its 40% test calculations, the Company has treated all of its investments, other than Government securities, bank deposits, demand deposits, and money market funds, as
“investment securities.”

1
 As the Staff is aware, in connection with proposing the temporary safe harbor afforded by Rule 3a-2 under the 1940 Act, the SEC acknowledged the possibility that an issuer that has sold substantial operating assets and intends to invest the proceeds pending the acquisition of new operating assets may
“argue that it is not in the ‘business’ of investing, reinvesting, owning, holding or trading in securities for purposes of determining whether it is an investment company.” See IM Guidance Update March 2017 No. 2017 –
03, quoting Transient Investment Companies, Investment Company Act Release No. 10943 (Nov. 16, 1979). The Company is not proposing to rely on the safe harbor of Rule 3a-2 because it may not meet the one-year period specified by the safe harbor, but believes that the SEC’s stated rationale behind adoption of the rule, of helping companies to avoid becoming “inadvertent” investment companies if
they temporarily hold a significant amount of cash as a result of the sale of an operating business, applies to the Company’s situation.

2
 While we acknowledge that time deposits/certificates of deposit could properly be considered to be investment
securities for purposes of the 1940 Act in the hands of companies with short-term liquidity needs, because of the risk that such companies’ financial positions could be adversely affected by the fact that certificates of deposit are not
generally redeemable before maturity, we believe that the certificates of deposit held by the Company, in the light of the Company’s particular circumstances, are essentially risk-free, as, without looking to any of its certificates of deposit,
regardless of their maturity periods, the Company has significantly more than enough immediately redeemable cash deposits to cover the needs of its businesses within the maturity periods of its certificates of deposit.

 [***] Certain information in this letter
has been omitted and submitted separately to the Staff. Confidential treatment has been requested with respect to the omitted information.

CONFIDENTIAL TREATMENT REQUESTED BY SOHU.COM LIMITED

 Securities and Exchange Commission

August 30, 2023

  Page
 3

 Using both of the assumptions described above, absent an exception, the Company would have
met the definition of “investment company” under Section 3(a)(1)(C) of the 1940 Act as of December 31, 2022 because, as is illustrated in calculations that the Company is providing to the Staff under separate cover on a
confidential, supplemental basis, the Company held investment securities with a value of more than 40% of the Company’s total assets (exclusive of Government securities and cash items) as of December 31, 2022 on an unconsolidated basis.
However, the Company is not in any event an investment company because of the applicability to the Company of the exception from Section 3(a)(1)(C) afforded by Section 3(b)(1) of the 1940 Act.

As the Staff knows, Section 3(b)(1) of 1940 Act provides, in relevant part, that, notwithstanding Section 3(a)(1)(C), an
“issuer primarily engaged, directly or through . . . wholly-owned . . . subsidiaries, in a business or businesses other than that of investing, reinvesting, owning, holding, or trading in securities” is not an investment company3. The Company primarily engages through its wholly-owned subsidiaries, including the business of those wholly-owned subsidiaries that is conducted through contracts with their corresponding
consolidated variable interest entities (“VIEs”)4, in businesses other than investing in securities, including online media, online video, and online games. Applying the five
factors test presented by the SEC in In re Tonopah Mining Co., 26 S.E.C. 426 (1947), (i) as noted above, the Company has never been engaged primarily in any business other than the operating businesses of its direct and indirect subsidiaries;
(ii) as evidenced by its periodic filings, press releases, and earnings release conference calls, the Company has never held itself out as, and does not propose to be, primarily engaged in, “the business of investing, reinvesting, or
trading in securities”; (iii) the Company’s directors and officers are focused almost exclusively on the performance and growth of the businesses of Sohu’s operating subsidiaries, and only occasionally focus on investment assets, and
when they occasionally do so it is only in order to ensure that the investments are managed in a way that will safely preserve the Company’s capital for deployment in those businesses or, from time to time, for repurchase of the Company’s
securities in the open market; (iv) as noted, those assets are invested prudently, with the goal of preserving them for future use in operations; there is no goal of generating any significant return for stockholders through those investments,
nor is there, nor has there been, any communication

3
 As the Staff is aware, the Staff has generally accepted the proposition that, because an issuer that fits
within Section 3(b)(1) is not “primarily engaged” in the business of investing in securities, the application of Section 3(a)(1)(A) is functionally excepted for an issuer that fits within the parameters of Section 3(b)(1).

4
 We are aware that some commenters have expressed some concern as to whether the fact that VIEs are not
technically wholly-owned subsidiaries could raise questions as to the availability of Section 3(b)(1) for issuers that operate aspects of their businesses through VIEs. However, we believe that (at least in the Company’ case) any such
concerns would be misplaced because (i) the contracts between the VIEs and the corresponding wholly-owned subsidiaries afford complete effective operating and financial controlling interests in the VIEs to the subsidiaries, (ii) as noted
at the end of this paragraph, substantially all cash is transferred from the VIEs to the Company’s wholly-owned subsidiaries on a monthly basis, (iii) through these contracts, the wholly-owned subsidiaries are clearly engaged in whatever
“business” is conducted by these VIEs, and substantially all of the economic attributes of the VIEs inure to their corresponding subsidiaries; (iv) since the Company’s VIEs do not retain more than a small amount of investments,
whether cash or otherwise, for any significant period of time, there should be no concern that they themselves are engaged in the business of investing in securities.

 [***] Certain information in this letter
has been omitted and submitted separately to the Staff. Confidential treatment has been requested with respect to the omitted information.

CONFIDENTIAL TREATMENT REQUESTED BY SOHU.COM LIMITED

 Securities and Exchange Commission

August 30, 2023

  Page
 4

from the Company to its stockholders suggesting that there is such a goal; and (v) the income generated by the Company’s investments is small compared to the revenues produced by the
operating businesses of the Company’s wholly-owned subsidiaries (including the net revenues of their corresponding VIEs, which are generally transferred substantially entirely to the wholly-owned subsidiaries on a monthly basis).

Governmental Regulations and Legal Uncertainties, page 71

Staff Comment:

2.
 Please state affirmatively whether you: (i) have been required to obtain any permission from or
complete any filing with the CSRC, and (ii) have been required to go through a cybersecurity review by the CAOC. If so, state affirmatively whether you have received all requisite permissions or approvals, or whether any have been denied. If
you have determined that no permissions are required, please clarify your basis for such determination, including whether you relied on the opinion of counsel.

Response:

 As a preliminary
matter, we note that the Company mistakenly included two references in the 2022 Form 20-F to the “CRSC,” when it intended to refer to the “CSRC,” which is the acronym typically used for the
China Securities Regulatory Commission. The Company used the correct acronym in several other places where it referenced the CSRC in the 2022 Form 20-F. To avoid any continuing confusion, we have also inserted
the corrected acronym into our transcription of the Staff’s comment above.

 The Company wishes to advise the Staff that the Company
(i) has not been required by the CSRC to obtain approval of or complete any filing with the CSRC with respect to any offering of the Company’s securities (collectively, the “Prior Offerings”), including the initial public
offering of the Company’s predecessor Sohu.com Inc. on Nasdaq, which was completed before the Overseas Listing Laws (as defined below) became effective, and (ii) has not been required to go through any cybersecurity review by the CAOC
under the Cybersecurity Laws (as defined below) as currently in effect.

 The Company also wishes to advise the Staff that, after
conducting the analyses discussed below, the Company has concluded that it is unlikely to be required to (i) obtain approval of or make a filing with the CSRC under the Overseas Listing Laws as they are currently being implemented by the CSRC
with respect to any of the Prior Offerings or (ii) go through any cybersecurity review by the CAOC under the Cybersecurity Laws (as defined below) as currently in effect, based on the Company’s businesses as they are currently operated.

 [***] Certain information in this letter
has been omitted and submitted separately to the Staff. Confidential treatment has been requested with respect to the omitted information.

CONFIDENTIAL TREATMENT REQUESTED BY SOHU.COM LIMITED

 Securities and Exchange Commission

August 30, 2023

  Page
 5

 (1) Procedures for Filing with the CSRC for Overseas Listings

As disclosed in the 2022 Form 20-F, the Trial Measures for the Administration of Overseas
Securities Offerings and Listings by Chinese Mainland Domestic Companies and the Notice on the Arrangements for the Filing Administration of Overseas Securities Offerings and Listings by Chinese Mainland Domestic Companies (collectively,
the “Overseas Listing Laws”) promulgated by the CSRC, which went into effect on March 31, 2023 and February 17, 2023, respectively, have established a new filing-based regime to regulate direct and indirect overseas
offerings and listings by Chinese mainland domestic companies. However, Chinese mainland domestic companies that had already listed in Offshore markets before March 31, 2023, such as the Company, are not currently required to file with the CSRC
for their previous public offerings and listings.

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