February 7, 2025

Ian Shan
Chief Financial Officer
JD.com, Inc.
20th Floor, Building A , No. 18 Kechuang 11 Street
Yizhuang Economic and Technological Development Zone
Daxing District, Beijing 101111
People   s Republic of China

       Re: JD.com, Inc.
           Form 20-F for Fiscal Year Ended December 31, 2023
           Response dated September 26, 2024
           File No. 001-36450
Dear Ian Shan:

        We have reviewed your September 26, 2024 response to our comment letter
and have
the following comment(s).

       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 12, 2024 letter.

Form 20-F for Fiscal Year Ended December 31, 2023
General

1.     We note your response to prior comment 4 and reissue in part. The Sample
Letters to
       China-Based Companies sought specific disclosure relating to the risk
that the PRC
       government may intervene in or influence your operations at any time,
which could
       result in a material change in your operations and/or the value of your
securities. The
       Sample Letters also sought specific disclosures relating to
uncertainties regarding the
       enforcement of laws and that the rules and regulations in China can
change quickly
       with little advance notice. Please revise further your disclosure in the
Summary of
       Risk Factors, Item 3, Key Information, and Risk Factors sections to
directly address
       these risks.
 February 7, 2025
Page 2

       Please contact Scott Stringer at 202-551-3272 or Joel Parker at
202-551-3651 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Rebekah Reed at 202-551-5332 or Donald Field at 202-551-3680 with any
other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:   Shu Du