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Mail Stop 3561
                                                           November 7, 2018

Qi Chen
Chairman of the Board of Directors and Chief Executive Officer
Meili Inc.
Zheshang Wealth Center, 12/F, Building No. 1, No. 99 Gudun Road
Xihu District, Hangzhou, 310012
People's Republic of China

       Re:    Meili Inc.
              Amendment No. 3 to Draft Registration Statement on Form DRS F-1
              Submitted October 26, 2018
              CIK No. 0001743971

Dear Mr. Chen:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in
our September 24, 2018 letter.

Notes to Unaudited Interim Condensed Consolidated Financial Statements

12. Intangible Assets, Net, page F-96

1.     We note your disclosure in Note 18 Related Party Transactions and
Balances that on
       July 18, 2018 you issued Series C-3 preferred shares in exchange for
"certain
       strategic business resources in accordance with a business cooperation
agreement
       with Tencent Group," and the strategic business resources were
recognized as
 Qi Chen
Meili Inc.
November 7, 2018
Page 2

       intangible assets with a fair value of RMB1,070,624. Noting the
significance of the
       intangible asset(s), please explain the nature of the asset(s), their
use in your
       operations and your basis for capitalization. Please also help us
understand how the
       business cooperation agreement with Tencent Group relates to or provides
for the
       purchase of these resources. Reference is made to ASC 350-30.

        You may contact Scott Stringer, Staff Accountant, at (202) 551-3571 or
Robyn
Manuel, Staff Accountant, at (202) 551-3823 if you have questions regarding
comments on
the financial statements and related matters. Please contact Parhaum J. Hamidi,
Staff
Attorney, at (202) 551-3421, Jennifer L pez, Staff Attorney, at 202-551-3792 or
me at (202)
551-3720 with any other questions.


                                                           Sincerely,

                                                           /s/ Jennifer L pez
for

                                                           Mara L. Ransom
                                                           Assistant Director
                                                           Office of Consumer
Products
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