July 15, 2019

Charles Yang
Chief Financial Officer
NetEase, Inc.
Building No. 7, West Zone,
Zhongguancun Software Park (Phase II)
No. 10 Xibeiwang East Road, Haidian District
Beijing 100193, People's Republic of China

       Re: NetEase, Inc.
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed April 26, 2019
           File No. 000-30666

Dear Mr. Yang:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your

       Please respond to this comment within ten business days by providing the
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your

       After reviewing your response to this comment, we may have additional

Form 20-F for the Fiscal Year Ended December 31, 2018

Financial Statements
Notes to the consolidated financial statements
20. Commitments and Contingencies
(b) Litigation, page F-34

1.     We note you reached a settlement agreement with PUBG in March 2019
regarding the
       complaint alleging copyright and trademark infringement as it relates to
your mobile
       games, Rules of Survival and Knives Out. Please describe to us your
accounting for the
       settlement and period of recognition. Further, tell us what
consideration you gave to
       providing disclosure when describing any known trends or uncertainties
with respect to
       revenues from Knives Out and Rules of Survival pursuant to Item 303(a)
of Regulation S-
       K. In this regard we note your disclosure that the growth in net
revenues from mobile
       games mainly resulted from games such as Knives Out which gained
popularity over the
 Charles Yang
NetEase, Inc.
July 15, 2019
Page 2
         course of 2018.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Tony Watson, Staff Accountant, at (202) 551-3318 or
Donna Di
Silvio, Staff Accountant, at (202) 551-3202 if you have questions regarding
comments on the
financial statements and related matters. Please contact Scott Anderegg, Staff
Attorney, at 202-
551-3342 or Lilyanna Peyser, Special Counsel, at 202-551-3222 with any other

FirstName LastNameCharles Yang                              Sincerely,
Comapany NameNetEase, Inc.
                                                            Division of
Corporation Finance
July 15, 2019 Page 2                                        Office of Consumer
FirstName LastName