November 26, 2018

Donghao Yang
Chief Financial Officer
Vipshop Holdings Ltd
No. 20 Hauhai Street
Liwan District, Guangzhou 510370
The People's Republic of China

       Re: Vipshop Holdings Ltd
           Form 20-F for Fiscal Year Ended December 31, 2017
           Filed April 19, 2018
           File No. 1-35454

Dear Mr. Yang:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 20-F for the Fiscal Year Ended December 31, 2017

Consolidated Statements of Income and Comprehensive Income, page F-7

1.    Please tell us your consideration of disclosing the changes in
accumulated balances of
      each component of other comprehensive loss included in accumulated other
      comprehensive loss recorded in equity. Refer to ASC 220-10-45-14A. Also,
tell us your
      consideration of disclosing the income tax effects attributable to
unrealized gains (losses)
      on available for sale investments and reclassification adjustments
included in
      comprehensive income and including a sub-total for the components that
make up other
      comprehensive (loss) gain. Refer to ASC 220-10-45-12 and 220-10-45-1B.b.
Note 4 Accounts Receivable, net, page F-42

2.    Please tell us your consideration of providing the disclosures in ASC
310-10-50-1 through
      34 related to your financing receivables. Additionally, please tell us
why your provision
 Donghao Yang
Vipshop Holdings Ltd
November 26, 2018
Page 2
         for doubtful accounts during each of the years in the table on page
F-42 do not agree to
         the provision for allowance for doubtful accounts presented in the
operating activities
         section of the statements of cash flows.
Note 11. Other Investments, page F-47

3.       Please tell is your consideration of the disclosures in ASC
320-10-50-6a.
Available-for-Sale Investments, page F-47

4.       Please tell us your consideration of the disclosures in ASC
320-10-50-9b.
Note 17 Short term loans and securitizations, page F-50

5.       The disclosures related to short-term loans do not reconcile to the
total recorded in the
         balance sheet. Please advise or revise.
Note 28. Segment information, page F-67

6.       Please tell us your consideration of disclosing the amount of
investments in equity method
         investees and total expenditures for additions to long-lived assets by
segment. Refer to
         ASC 280-10-50-25a and b. Also, tell us if equity in the net income of
investees accounted
         for by the equity method, interest income and interest expense by
segment is provided to
         your chief operating decision maker. If so, tell us your consideration
of the disclosures in
         ASC 280-10-50-22.
       In closing, 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 Tony Watson, Staff Accountant, at (202) 551-3318 or
William
H.Thompson, Accounting Branch Chief, at (202) 551-3344 with any questions.



FirstName LastNameDonghao Yang                                 Sincerely,
Comapany NameVipshop Holdings Ltd
                                                               Division of
Corporation Finance
November 26, 2018 Page 2                                       Office of
Consumer Products
FirstName LastName