[[Letterhead of NetEase.com, Inc.] September 30, 2009 Mr. H. Christopher Owings, Assistant Director Mr. John Fieldsend, Attorney-Adviser Division of Corporation Finance 100 F Street, NE Re: NetEase.com, Inc. (the Company) Annual Report on Form 20-F for the Year Ended December 31, 2008 Filed June 30, 2009 File No. 0-30666 (the 2008 Form 20-F) Dear Mr. Owings and Mr. Fieldsend: Letter]
[[Letterhead of NetEase.com, Inc.] September 30, 2009 Mr. H. Christopher Owings, Assistant Director Mr. John Fieldsend, Attorney-Adviser Division of Corporation Finance 100 F Street, NE Re: NetEase.com, Inc. (the Company) Annual Report on Form 20-F for the Year Ended December 31, 2008 Filed June 30, 2009 File No. 0-30666 (the 2008 Form 20-F) Dear Mr. Owings and Mr. Fieldsend: Letter]
[[Letterhead of NetEase.com,] September30, 2009 Mr.H. Christopher Owings,sistant Director Mr.John Fieldsend, Attorney-Adviser STYLE="font-family:Times New Roman" SIZE="2">Division ofrporation Finance 100 F Street, NE Re: NetEase.com, (thempany) Annual Report on Form 20-F for the Year Ended December31, 2008 Filed June30, 2009 File No. 0-30666 (the 2008 Form 20-F)]
[[Letterhead of NetEase.com,] September30, 2009 Mr.H. Christopher Owings,sistant Director Mr.John Fieldsend, Attorney-Adviser STYLE="font-family:Times New Roman" SIZE="2">Division ofrporation Finance 100 F Street, NE Re: NetEase.com, (thempany) Annual Report on Form 20-F for the Year Ended December31, 2008 Filed June30, 2009 File No. 0-30666 (the 2008 Form 20-F)]
[[Letterhead of NetEase.com,] September30, 2009 Mr.H. Christopher Owings,sistant Director Mr.John Fieldsend, Attorney-Adviser STYLE="font-family:Times New Roman" SIZE="2">Division ofrporation Finance 100 F Street, NE Re: NetEase.com, (thempany) Annual Report on Form 20-F for the Year Ended December31, 2008 Filed June30, 2009 File No. 0-30666 (the 2008 Form 20-F)]
[[Letterhead of NetEase.com,] September30, 2009 Mr.H. Christopher Owings,sistant Director Mr.John Fieldsend, Attorney-Adviser STYLE="font-family:Times New Roman" SIZE="2">Division ofrporation Finance 100 F Street, NE Re: NetEase.com, (thempany) Annual Report on Form 20-F for the Year Ended December31, 2008 Filed June30, 2009 File No. 0-30666 (the 2008 Form 20-F)]
[[Letterhead of NetEase.com,] September30, 2009 Mr.H. Christopher Owings,sistant Director Mr.John Fieldsend, Attorney-Adviser STYLE="font-family:Times New Roman" SIZE="2">Division ofrporation Finance 100 F Street, NE Re: NetEase.com, (thempany) Annual Report on Form 20-F for the Year Ended December31, 2008 Filed June30, 2009 File No. 0-30666 (the 2008 Form 20-F)]
[[Letterhead of NetEase.com,] September30, 2009 Mr.H. Christopher Owings,sistant Director Mr.John Fieldsend, Attorney-Adviser STYLE="font-family:Times New Roman" SIZE="2">Division ofrporation Finance 100 F Street, NE Re: NetEase.com, (thempany) Annual Report on Form 20-F for the Year Ended December31, 2008 Filed June30, 2009 File No. 0-30666 (the 2008 Form 20-F)]
[developing and launching games, updating existing games at a faster rate, and licensing games from third parties, and please discuss how these actions have impacted you and will impact you in future periods. You state that you expect that your fixed costs in connection with your Internet portal business will increase without a corresponding increase]
[developing and launching games, updating existing games at a faster rate, and licensing games from third parties, and please discuss how these actions have impacted you and will impact you in future periods. You state that you expect that your fixed costs in connection with your Internet portal business will increase without a corresponding increase]
