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                             August 4, 2023

       Julius Rong Luo
       Chief Financial Officer
       Baidu, Inc.
       Baidu Campus
       No. 10 Shangdi 10th Street
       Haidian District, Beijing 100085
       The People   s Republic of China

                                                        Re: Baidu, Inc.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 000-51469

       Dear Julius Rong Luo:

              We have limited our review of your filing to the submission
and/or disclosures as
       required by Item 16I of Form 20-F 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.

                                                        After reviewing your
response to these comments, we may have additional comments.

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

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 222

   1.                                                   We note your statement
that you reviewed your register of members and public filings
                                                        made by your
shareholders in connection with your required submission under paragraph
                                                        (a). Please
supplementally describe any additional materials that were reviewed and tell
                                                        us whether you relied
upon any legal opinions or third party certifications such as
                                                        affidavits as the basis
for your submission. In your response, please provide a similarly
                                                        detailed discussion of
the materials reviewed and legal opinions or third party
                                                        certifications relied
upon in connection with the required disclosures under paragraphs
                                                        (b)(2) and (3).
   2.                                                   We note that your
disclosures pursuant to Items 16I(b)(2), (b)(3), and (b)(5) are provided
                                                        for    Baidu, Inc. or
the VIEs.    We also note that your list of subsidiaries in Exhibit 8.1
                                                        appears to indicate
that you have subsidiaries in Hong Kong and countries outside China
 Julius Rong Luo
Baidu, Inc.
August 4, 2023
Page 2
      that are not included in your VIEs. Please note that Item 16I(b) requires
that you provide
      disclosures for yourself and your consolidated foreign operating
entities, including
      variable interest entities or similar structures.

             With respect to (b)(2), please supplementally clarify the
jurisdictions in which
           your consolidated foreign operating entities are organized or
incorporated and
           provide the percentage of your shares or the shares of your
consolidated operating
           entities owned by governmental entities in each foreign jurisdiction
in which you
           have consolidated operating entities in your supplemental response.
             With respect to (b)(3) and (b)(5), please provide the required
information for you and
           all of your consolidated foreign operating entities in your
supplemental response.
3.    In order to clarify the scope of your review, please supplementally
describe the steps you
      have taken to confirm that none of the members of your board or the
boards of your
      consolidated foreign operating entities are officials of the Chinese
Communist Party. For
      instance, please tell us how the board members    current or prior
memberships on, or
      affiliations with, committees of the Chinese Communist Party factored
into your
      determination. In addition, please tell us whether you have relied upon
third party
      certifications such as affidavits as the basis for your disclosure.
4.    With respect to your disclosure pursuant to Item 16I(b)(5), we note that
you have included
      language that such disclosure is    to our knowledge.    Please
supplementally confirm
      without qualification, if true, that your articles and the articles of
your consolidated
      foreign operating entities do not contain wording from any charter of the
Chinese
      Communist Party.
        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.

      Please contact Jimmy McNamara at 202-551-7349 or Christopher Dunham at
202-551-
3783 with any questions.




                                                            Sincerely,
FirstName LastNameJulius Rong Luo
                                                            Division of
Corporation Finance
Comapany NameBaidu, Inc.
                                                            Disclosure Review
Program
August 4, 2023 Page 2
cc:       Shu Du
FirstName LastName