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                             December 16, 2022

       Anqiang Chen
       Financial Controller
       Tuniu Corporation
       Tuniu Building No. 32
       Suningdadao, Xuanwu District
       Nanjing, Jiangsu Province 210042
       The People   s Republic of China

                                                        Re: Tuniu Corporation
                                                            Form 20-F for
Fiscal Year Ended December 31, 2021
                                                            Response dated
November 16, 2022
                                                            File No. 001-36430

       Dear Anqiang Chen:

              We have reviewed your November 16, 2022 response to our comment
letter 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. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       November 3, 2022 letter.

       Form 20-F for Fiscal Year Ended December 31, 2021

       Item 3. Key Information
       D. Risk Factors, page 11

   1.                                                   We note from your
revised disclosure in response to prior comment 2 that    the laws,
                                                        regulations and the
discretion of mainland China governmental authorities discussed in
                                                        this annual report are
expected to apply to mainland China entities and businesses, rather
                                                        than entities or
businesses in Hong Kong and Macau which operate under different sets of
                                                        laws from mainland
China.    Therefore, we reissue prior comment 2 in part.

                                                        Where appropriate,
explain how commensurate laws in Hong Kong and Macau differs
 Anqiang Chen
Tuniu Corporation
December 16, 2022
Page 2
         from PRC law and describe any risks and consequences to the company
s operations in
         Hong Kong and Macau, associated with those laws. For example, please
clarify whether a
         different set of laws apply to entities or businesses in Hong Kong and
Macau as it relates
         to the disclosure in the following risk factors on pages 3 and 35,
respectively:

                   Risks and uncertainties arising from the legal system in
China, including risks and
              uncertainties regarding the enforcement of laws and quickly
evolving rules and
              regulations in China, could result in a material adverse change
in our operations and
              the value of our ADSs   ; and

                   We conduct our business in China. Our operations in China
are governed by PRC
              laws and regulations. The PRC government has significant
oversight over the conduct
              of our business, and may intervene or influence our operations as
the government
              deems appropriate to advance regulatory and societal goals and
policy positions      ).

         As part of your revised disclosure, address the risk that that the
Chinese government may
         intervene or influence your operations in Hong Kong and Macau at any
time.
       You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or
Shannon
Buskirk, Staff Accountant, at 202-551-3717 with any questions.



FirstName LastNameAnqiang Chen                                 Sincerely,
Comapany NameTuniu Corporation
                                                               Division of
Corporation Finance
December 16, 2022 Page 2                                       Office of Energy
& Transportation
FirstName LastName