July 8, 2019

Cindy Xiaofan Wang
Chief Financial Officer
Ctrip.com International, Ltd.
968 Jin Zhong Road
Shanghai 200335
People's Republic of China

       Re: Ctrip.com International, Ltd.
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed March 15, 2019
           File No. 001-33853

Dear Ms. Wang:

        We have reviewed your June 24, 2019 response to our comment letter and
have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
June 10, 2019 letter.

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

Operating and Financial Review and Prospects
Results of Operations, page 56

1.     Your note response to prior comment 1 did not address what consideration
was given to
       providing quantitative disclosure of hotel room nights, accommodation
reservation
       volume, and ticketing volume. Although we note that you have provided
qualitative
       disclosure of the key drivers, it appears that quantification of these
drivers would be useful
       to add context to your discussion of period-over-period changes in
revenue. Please revise
       to provide quantification or tell us why you believe it would not be
useful to an investor's
       understanding of your results of operations. We also note that MAU and
transacting user
       data was provided in the call in response to specific investor
inquiries. Please explain in
 Cindy Xiaofan Wang
Ctrip.com International, Ltd.
July 8, 2019
Page 2
       greater detail why you believe quantitative disclosure of MAU and
transacting user data is
       not warranted considering that your investors requested such data and it
therefore appears
       to provide useful information to investors.
       You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or
Christine Dietz,
Assistant Chief Accountant at (202) 551-3408 with any questions.



                                                            Sincerely,

FirstName LastNameCindy Xiaofan Wang                        Division of
Corporation Finance
                                                            Office of
Information Technologies
Comapany NameCtrip.com International, Ltd.
                                                            and Services
July 8, 2019 Page 2
cc:       Julie Gao
FirstName LastName