Mail Stop 4628

                                                             September 25, 2018

Via E-mail
Arkady Volozh
Chief Executive Officer
Yandex N.V.
Schiphol Boulevard 165
Schiphol 1118 BG, The Netherlands

       Re:     Yandex N.V.
               20-F Fiscal Year Ended December 31, 2017
               Filed March 27, 2018
               File No. 1-35173

Dear Mr. Volozh:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comment.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comment, we 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.

General

   1. The flights.Yandex.com website offers flights serving North Korea and
Sudan.
      Additionally, we are aware of news reports indicating that Yandex.market
was chosen by
      Samsung to become the main platform to search for goods using Bixby, and
that Bixby's
      voice capabilities have expanded to more than 200 countries, including
Syria.

       North Korea, Sudan and Syria are designated by the U.S. Department of
State as state
       sponsors of terrorism, and are subject to U.S. economic sanctions and/or
export controls.
       Please describe to us the nature and extent of any past, current, and
anticipated contacts
       with North Korea, Sudan and Syria, including contacts with their
governments, whether
       through subsidiaries, affiliates, partners, customers, joint ventures or
other direct or
       indirect arrangements. Please also discuss the materiality of those
contacts, in
       quantitative terms and in terms of qualitative factors that a reasonable
investor would
 Arkady Volozh
Yandex N.V.
September 25, 2018
Page 2

       deem important in making an investment decision. Tell us the approximate
dollar
       amounts of revenues, assets and liabilities associated with those
countries for the last
       three fiscal years and the subsequent interim period. Address for us the
potential impact
       of the investor sentiment evidenced by divestment and similar
initiatives that have been
       directed toward companies that have operations associated with
U.S.-designated state
       sponsors of terrorism.

        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 Daniel Leslie, Staff Attorney, at (202) 551-3876 or me
at (202) 551-
3470 if you have any questions about the comment or our review.

                                                           Sincerely,

                                                           /s/ Cecilia Blye

                                                           Cecilia Blye, Chief
                                                           Office of Global
Security Risk

cc:    Barbara Jacobs
       Assistant Director
       Division of Corporation Finance

       Roman Krupenin
       Legal Counsel
       Yandex N.V.

       Timothy & Corbett
       Morgan, Lewis & Bockius UK LLP