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                              August 25, 2023

       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
                                                            Filed April 27, 
2023
                                                            File No. 000-30666

       Dear William Lei Ding:

              We have reviewed your August 4, 2023 response to our comment 
letter and have the
       following comments. In some of our comments, we may ask you to provide 
us with information
       so we may better understand your disclosure.

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in 
your response.

              After reviewing your response to these comments, we may have 
additional
       comments. Unless we note otherwise, our references to prior comments are 
to comments in our
       July 21, 2023 letter.

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

       General

   1.                                                   We note your response 
to prior comment 3 regarding the proposed treatment of certain
                                                        deposit arrangements    
with original maturities of twelve months or fewer    as    cash    for
                                                        purposes of Rule 3a-1 
under the Investment Company Act of 1940. Based on the
                                                        information you have 
provided to date, we are unable to concur with your position that
                                                        these arrangements can 
be treated as cash items for purposes of Rule 3a-1. In this regard,
                                                        we note that you have 
not provided a sufficiently detailed description of the material terms
                                                        of the deposit 
arrangements, together with an analysis regarding why, specifically, such
                                                        terms establish that 
the deposit arrangements may be treated as cash consistent with
 William Lei Ding
NetEase, Inc.
August 25, 2023
Page 2
         applicable Commission or staff guidance. Please provide such 
description and analysis to
         the extent that you believe that it would establish that these deposit 
arrangements are
         eligible to be treated as cash items under the rule. Please also 
clarify whether you still
         believe the company is eligible to rely on Rule 3a-1 without treating 
the relevant deposit
         arrangements as cash items.
        You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 
or Christine
Dietz, Senior Staff Accountant, at (202) 551-3408 if you have any questions.



FirstName LastNameWilliam Lei Ding                            Sincerely,
Comapany NameNetEase, Inc.
                                                              Division of 
Corporation Finance
August 25, 2023 Page 2                                        Office of 
Technology
FirstName LastName