Mail Stop 3561
                                                           September 24, 2018

Qi Chen
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. 1 to Draft Registration Statement on Form DRS F-1
              Submitted September 7, 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 August 29, 2018 letter.

Management's Discussion and Analysis

Results of Operations

Year ended March 31, 2018 compared to year ended March 31, 2017, page 83

1.     We note your response to comment 18 and your revised disclosure on page
       19. Please tell us your consideration of providing similar disclosure in
Management's
 Qi Chen
Meili Inc.
September 24, 2018
Page 2

       Discussion and Analysis pursuant to Item 303(a)(3)(ii) of Regulation S-K
and related
       Instructions.

2.     We note your response to comment 19. Please disclose the information
provided in
       your correspondence or tell us why you believe this information should
not be
       disclosed.

Business

Our Users

Fashion Influencers, page 106

3.     Your disclosure in response to comment 25 on page 107 states that "[you]
generally
       do not provide any significant compensation to opinion leaders and
content creators."
       Please revise to discuss the instances in which you do provide
significant
       compensation to opinion leaders and content creators.

Fashion Content

Content Type and Format, page 108

4.     We note your revised disclosure in response to comment 23 that "[l]ive
video
       broadcasts contributed RMB1.7 billion, or 11.8% of our total GMV for the
year
       ended March 31, 2018, compared with RMB0.2 billion, or 1.4% for the year
ended
       March 31, 2017." Please revise to explain how you determined the total
GMV
       contributed by live video broadcasts during the fiscal periods
discussed.

Exhibits

5.     We note you have redacted certain information from your exhibits, such
as Exhibit
       10.4. If you intend to seek confidential treatment for this information,
please ensure
       you follow the requirements set forth in Rule 406 of the Securities Act
or tell us why
       you do not believe you need to do so. Otherwise, please file fully
unredacted
       versions of your exhibits. For further guidance, please refer to the
Division's Staff
       Legal Bulletin No. 1A (July 11, 2011).

6.     We note a mandatory arbitration provision in Section 12.12(b) of the
Eleventh
       Amended and Restated Shareholders Agreement. Please tell us whether this
provision
       applies to claims made under the federal securities laws of the United
States.
 Qi Chen
Meili Inc.
September 24, 2018
Page 3


        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,
Special
Counsel, 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