United States securities and exchange commission logo
March 27, 2024
William Lei Ding
Chief Executive Officer
NetEase, Inc.
NetEase Building
No. 599 Wangshang Road
Binjiang District, Hangzhou, 310052
People s Republic of China
Re: NetEase, Inc.
Form 20-F for the
Fiscal Year Ended December 31, 2022
Response dated
September 22, 2023
File No. 000-30666
Dear William Lei Ding:
We have reviewed your September 22, 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.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1. We note your September
22, 2023 response to the staff s questions about your treatment
of certain deposit
arrangements with original maturities of twelve months or fewer for
purposes of Rule 3a-1
under the Investment Company Act of 1940, as amended
( Company Act ).
Please note that, based on your description of such assets, we do not
necessarily agree with
your view that the deposit arrangements may be treated as cash
items for purposes
of Rule 3a-1. Please supplement the risk factor in your June 30, 2023
response regarding the
company s status under the Company Act to reflect the foregoing
and provide us with the
proposed disclosures that you will include in future filings.
William Lei Ding
FirstName LastNameWilliam Lei Ding
NetEase, Inc.
Comapany
March NameNetEase, Inc.
27, 2024
March2 27, 2024 Page 2
Page
FirstName LastName
Please contact Megan Akst at 202-551-3407 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of Technology