United States securities and exchange commission logo
November 7, 2023
Anqiang Chen
Financial Controller
Tuniu Corporation
Tuniu Building No. 32
Suningdadao, Xuanwu District
Nanjing, Jiangsu Province 210042
The People s Republic of China
Re: Tuniu Corporation
Form 20-F for the
Fiscal Year Ended December 31, 2022
Response dated
October 26, 2023
File No. 001-36430
Dear Anqiang Chen:
We have reviewed your October 26, 2023 response to our comment
letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our September 29, 2023
letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 144
1. We note your response
to prior comment 1. As previously requested, please explain to us
in detail how you
reasonably concluded that the three employee directors who have a CCP
official title of
secretary or deputy secretary of the Tuniu Chinese Communist Party
Committee are not CCP
officials given their official titles, roles and responsibilities. In
doing so, please
describe in detail the roles and responsibilities corresponding to each
official title.
Please contact Jennifer Thompson at 202-551-3737 or Andrew Mew at
202-551-3377
with any other questions.
Anqiang Chen
Tuniu Corporation
November 7, 2023
Page 2
Sincerely,
FirstName LastNameAnqiang Chen
Division of Corporation Finance
Comapany NameTuniu Corporation
Disclosure Review Program
November 7, 2023 Page 2
cc: Haiping Li
FirstName LastName