December 5, 2013
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20459
Attn: Mark P. Shuman, Esq., Branch Chief - Legal
| Re: | Changyou.com Limited |
Form 20-F for the Fiscal Year Ended December 31, 2012
Filed on February 28, 2013
File No. 001-34271
Dear Mr. Shuman:
In connection with the response of Changyou.com Limited (“Changyou”), dated the date hereof, to a letter from the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) to Alex Ho, Chief Financial Officer of Changyou, dated November 25, 2013 (the “Comment Letter”), Changyou acknowledges that:
| • | Changyou is responsible for the adequacy and accuracy of the disclosures in the Form 20-F referenced in the Comment Letter; |
| • | Staff comments or changes to disclosure in response to Staff comments do not foreclose the SEC from taking any action with respect to the referenced filings; and |
| • | Changyou may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States. |
| Sincerely, |
| /s/ Alex Ho |
| Alex Ho, |
| Chief Financial Officer |